ML20046C079

License Change Application 234 to License NPF-1,proposing Revised TS to Reflect Permanently Defueled Status of Plant

ML20046C079
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	07/31/1993
From:	Cross J, Quennoz S PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20046C080	List: ML20046C079 ML20046C083
References
NUDOCS 9308090182
Download: ML20046C079 (95)

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Portland Gereral ElectricConputy James E. Cross Vice President and Chief Nuclear Officer i

July 31,1993 t

Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Dear Sirs:

License Change Application 234 -

Permanently Defueled Technical Snecifications The purpose of this letter is to transmit License Change Application (LCA) 234, which requests changes to Possession Only License NPF-1. This LCA proposes to change Appendix A, Trojan Technical Specifications (TTS), to reflect the permanently defueled status of the plant.

The termination ofoperations at the Trojan Nuclear Plant and the conversion of the operating license.to a possession only license has rendered many of the existing provisions of the technical specifications inappropriate. Portland General Electric (PGE) has developed Permanently Defueled Technical Specifications (PDTS) for the Trojan Nuclear Plant using NUREG-1431,

" Standard Technical Specifications, Westinghouse Plants," as the basis for the PDTS scope and format.

The improved Standard Technical Specifications contained in NUREG-1431 are the result of an extensive effort by the NRC staff, the Westinghouse Owners Group, and the Nuclear Managemerit and Resources Council. These improved Standard Technical Specifications were developed to rueet the goals and criteria set forth in the interim Commission Policy Statement for Nuclev Power Reactors, " Proposed Policy Statement on Technical Improvements for Nuclear Pow;r Reactors," dated February 6,1987.

Attachment I to this letter provides the background for and description of the proposed changes to Appendix A ofPossession Only License NPF-1. Attachment Il contains the no significant hazards consideratica determination. Attachment III to this letter provides a copy of the proposed PDTS modifying Appendix A ofPossession Only License NPF-1. Attachment IV contains the proposed Bases for the PDTS.

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Document Control Desk

- July 31,1993 Page 2 PGE requests that NRC approval of the PDTS, modifying Appendix A of Possession Only i

License NPF 1, include a provision that allows PGE to determine the date that the PDTS will be implemen..ed. This flexibility in scheduling is being requested due to the number of proposed changes and the additional administrative controls which are to be implemented concurrently with the PDTS. PGE will notify the NRC of the proposed implementation date for the PDTS.

Sincerely, A&==g S. M. Quennoz for J. E. Cross Attachment I Background and Description of Change Attachment Il No Significant Hazards Consideration Determination Attachment III Proposed Permanently Defueled Technical Specifications Attachment IV Proposed Permanently Defueled Technical Specifications Bases i

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Mr. Bobby H. Faulkenberry Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. David Stewart-Smith State ofOregon Department ofEnergy Mr. James F. Melfi NRC Resident Inspector Trojan Nuclear Plant

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STATE OF OREGON)

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COUNTY OF COLUMBIA) i

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I, S. M. Quennoz, being duly sworn, subscribe to and say that I am the General Manager, Trojan Plant for Portland General Electric Company, the applicant herein; that I have full authority to execute tlJs 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.

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Date July 31,1993 f

AM i

S. M. Quennoz U

General Manager l

Trojan Plant I

On this day personally appeared before me S. M. Quennoz, to me known to be the individual u ho executed the foregoing instrument, and acknowledged that he signed the same as his free act.

GIVEN under sny hand and seal this 31" day of July,1993.

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,? m i). 5 CHAMd Notary Public in and for the State of Oregon Residing at (t/ si tc4)

My commission expires 3 -RS 'lY l

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UhTTED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of

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PORTLAND GENERAL ELECTRIC COMPANY,

) Docket 50-344 THE CITY OF EUGENE, OREGON, AND

) Possession Only License NPF-1 PACIFIC POWER & LIGHT COMPANY

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(TROJAN NUCLEAR PLANT)

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CERTIFICATE OF SERVICE I hereby certify that copies of License Change Application 234, to the Possession Only License for Trojan Nuclear Plant, dated July 31,1993, have been served on the following by hand delivery or by deposit in the United States mail, first class, this 31' day of July 1993:

State of Oregon Department of Energy 625 Marion St NE Salem OR 97310 Mr. Michael J. Sykes Chairman of County Commissioners Colombia County Courthouse St. Helens OR 97051 I

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,1 H. K. Chernoff, Manager Nuclear Licensing Department Technical Functions On this day personally appeared before me H. K. Chernoff, 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 my hand and seal this 31" day of July 1993.

Mna))H.OS7tNhw)

Notary Public in and for the State of Oregon A

Residing at c'Cl 211eil My commission expires 8"d8 - ?Y 1

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I Page1of41

Background

Portland General Electric (PGE) has permanently ceased power operation at the Trojan facility.

Subsequently PGE removed the reactor fuel from the reactor vessel and placed it in storage in the spent fuel pool. The NRC has issued amendment 190 to Facility Operating License NPF-1 removing the authority to operate the reactor and converting the former operating license to a possession only license. In accordance with 10 CFR 50.36, Appendix A to the license contains technical specifications that place various limitations on the operation of the facility. The termination of reactor operations at the Trojan Nuclear Plant and the conversion of the operating license to a possession only license has rendered many of the existing provisions of the technical specifications moot or inappropriate. The purpose of this submittal is to propose revised technical specifications appropriate for the current status of the facility.

PGE used NUREG-1431, " Standard Technical Specifications, Westinghouse Plants," as the basis for the scope and format of the proposed Permanently Defueled Technical Specifications (PDTS).

The improved standard technical specifications contained in NUREG-1431 are the result of an extensive effort by the NRC staff, the Westinghouse Owners Group, and the Nuclear i

Management and Resources Council. These improved standard technical specifications were developed to meet the goals and criteria set forth in the interim Commission Policy Statement for Nuclear Power Reactors, dated Febmary 6,1987.

1 The interim Commission Policy Statement established three criteria to define the scope of equipment and parameters included in the improved technical specifications. These criteria were l

developed for operating reactors and iocused on instmmentation to detect degradation of the reactor coolant system pressure boundary and on equipment or process variables that affect the integrity of fission product barriers during design bases accidents or transients. PGE used slightly modified forms of the criteria, more appropriate for a permanently defueled facility, to ensure that equipment or process variables important to the safe storage ofirradiated fuel were not overlooked. PGE then used these modified criteria to evaluate each existing Trojan Technical Specification (TTS) to determine ifit should be retained in the PDTS.

Criterion 1 of the interim Commission Policy Statement states that the technical specifications should include installed instrumentation used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. Since no fuel is present in the reactor coolant system at the Trojan facility, this criterion is not applicable as originally written. PGE modified this criterion, however, to apply to

.talled instrumentation used to detect, and indicate in the control room, a significant abnorma degradation in the integrity of the spent fuel pool.

Criterion 2 of the interim Commission Policy Statement states that the technical specifications should include process variables that are initial conditions of a Design Basis Accident (DBA) or transient analysis that either assume the failure of or present a challenge to the integrity of a fission product banier. This criterion remains applicable to a permanently defueled facility with the exception of the reference to transient analyses, and this phrase was deleted in the criterion used to develop the PDTS. The scope of DBAs applicable to a permanently defueled facility is

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF Attachment I Page 2 of 41 i

also markedly reduced from those postulated for an operating plant. The scope of DBAs

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applicable to the Trojan facility is discussed in more detail below.

Criterion 3 of the interim Commission Policy Statement states that the technical specifications should include structures, systems, or components that are part of the primary success path and which function or actuate to mitigate a Design Basis Accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. This criterion also remains applicable to a permanently defueled facility with the exception of the reference to i

transients. The reference to transients was deleted in the criterion used to develop the PDTS.

The qualifying phrase ".. that is pan of the primary success path and which functions or actuates to mitigate a Design Basis Accident.." was deleted in favor of a more general statement that structures, systems, or components that function to prevent or mitigate the specified DBAs should be included in the proposed PDTS. The scope of DBAs applicable to a permanently defueled facility is also markedly reduced from those postulated for an operating plant. The scope of DBAs applicable to the Trojan facility is discussed in more detail below.

Following is a comparison of the criteria of the interim Commission Policy Statement and those used in the development of the Trojan PDTS.

Criterion Interim Commission Trojan Permanently Defueled Policy Statement Technical Specifications 1

Installed instmmentation that is used to Installed instrumentation that is used to detect, and indicate in the control detect, and indicate in the control room, a significant abnormal room, a significant degradation of the degradation of the reactor coolant spent fuel poolintegrity.

pressure boundary.

2 A process variable that is an initial A process variable that is an initial condition of a Design Basis Accident condition of a Design Basis Accident (DBA) or Transient Analyses that (DB A) that either assumes the failure either assumes the failure of or presents ofor presents a challenge to the a challenge to the integrity of a fission integrity of a fission product barrier product barrier.

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A structure, system, or component that A structure, system, or component is part of the primary success path and that functions to prevent or mitigate a which functions or actuates to mitigate Design Basis Accident that either i

a Design Basis Accident or Transient assumes the failure ofor presents a that either assumes the failure ofor challenge to the integrity of a fission l

presents a challenge to the integrity of product barrier a fission product barrier.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 3 of 41 Section 15 of the SAR describes the DBA scenarios that were applicable to the Trojan Nuclear Plant during power operations. However, with the permanent shutdown of the Trojan Nuclear Plant and the conversion of the operating license to a possession only license, most of the accident scenarios postulated in the SAR are no longer possible. PGE is revising the SAR to reflect the current facility status. These postulated accidents are listed in the following table and discussed below.

SAR Section 15 Design Bases Accidents Postulated Accident Current Applicability 15.1 - Increase in Heat Removal by the N/A i

Secondary System 15.2 - Decrease in Heat Removal by the N/A Secondary System 15.3 -- Decrease in Reactor Coolant System N/A Flow Rate 15.4 - Reactivity and Power Distribution N/A Anomalies 15.5 -- Increase in Reactor Coolant Inventory N/A 15.6 - Decrease in Reactor Coolant N/A Inventory 15.7 - Radioactive Release from a (see Subsections below)

Subcomponent or System 15.7.1 -- Radioactive Gas Waste Applicable System Leak or Failure 15.7.2 -- Radioactive Liquid Waste N/A System Leak or Failure (Not Considered in Trojan Design Bases per Current SAR) 15.7.3 -- Pm:!aec Radioactive Release Due to Liquid Tank Applicable Failure 15.7.4 - Design Basis Fuel Handling Applicable Accidents 15.7.5 - Spent Fuel Cask Drop Applicable Accident 15.8 - Anticipated Transients without N/A SCRAM

I Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 i

License NPF-1 Page 4 of 41 SAR Section 15 Design Bases Accidents l

Postulated Accident Current Applicability i

15.9 - Evaluation of Safety Analysis for l

Mixed Fuel Design Core and N/A

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Increased Steam Generator Tube

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The most severe postulated accidents for nuclear power plants involve damage to the nuclear reactor core and the release oflarge quantities of fission products to the reactor coolant system.

The forced flow of water through the reactor coolant system (RCS) removes the heat generated by the reactor. The RCS, operating at high temperatures and pressures, transfers this heat through the steam generator tubes to the secondary system. Many of the accident scenarios postulated in the SAR involve failures or malfunctions in these systems that could affect the reactor core. With the termination of reactor operations at the Trojan facility.and the conversion of the operating license to a possession only license, such accidents are no longer possible. The t

reactor, RCS and secondary system are no longer in operation. The irradiated fuel is now stored

- in the spent fuel pool and these systems serve no function related to the storage ofirradiated fuel in the spent fuel pool. Therefore, the postulated accidents involving failure or malfunction of I

these systems are no longer applicable. These include SAR Sections 15.1 through 15.6 and Sections 15.8 and 15.9 as indicated on the above table.

t The postulated accidents described in SAR section 15.7, " Radioactive Release from a i

Subcomponent or System," involve the release of radioactive materials from systems other than l

the RCS and secondary system. This includes a leak or failure in the Radioactive Gas Waste System (Section 15.7.1); a leak due to failure of a liquid radioactive waste tank (Section 15.7.3) and a fuel handling accident (Section 15.7.4). The termination of reactor operations at the Trojan

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facility did not eliminate these postulated events. However, since the production of radioactive gases and liquids associated with r actor operation has ceased, radioactive decay has eliminated much of the inventory of such materials that existed at the time the reactor was permanently '

3 shutdown. Therefore the analyses currently contained in the SAR are overly conservative. PGE l

is revising the SAR to reflect the current status of the facility. The specific effects on the i

4 accident scenarios discussed in Section 15.7 are discussed in more detail below.

l SAR Section 15.7.1 provides an analysis of a postulated failure of the Waste Gas Decay Tanks f

(WGDTs). During reactor operations the WGDTs are used to store and permit the decay of radioactive gases to reduce or prevent the normal release of radioactive materials to the atmosphere. The radioactive contents of the WGDTs are principally the noble gases krypton and xenon, the particulate daughters of some of the krypton and xenon isotopes, and trace quantities of halogens. These noble gases were generated from fission during operation of the reactor.

i Since the reactor is permanently shutdown, such gases are no longer generated at the Trojan i

facility. Further, within six months after shutdown of the reactor, the gases in the WGDTs have decayed such that there remains in the system only a very small fraction of the inventory accumulated dunng power operation. Therefore, there is no possibility of a release from the l

- Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I l

Page 5 of 41.

WGDTs that would result in doses beyond the exclusion area exceeding a small fraction of the limits of10 CFR 100.

4 SAR Section 15.7.3 provides an analysis of a postulated failure of the Chemical and Volume Control System (CVCS) holdup tank. The CVCS holdup tank failure in an operating reactor has the largest atmospheric release source in the CVCS due to its large volume and the fact that it contains reactor coolant covered by gas from the waste gas system. However, within six months after the reactor ceased operation, the radioactive materials available for release off-site have decayed sufficiently and/or have been vented such that the activity levels are bounded by the l

WGDT rupture discussed above. Liquid efiluent stored in the tank.s are contained such that they l

do not escape the auxiliary or fuel buildings. Therefore, the postulated rupture of the CVCS l

holdup tank would not result in doses beyond the exclusion boundary that would exceed a small l

fraction of the limits of10 CFR 100.

SAR Section 15.7.4 discusses the design basis fuel handling accident. Fuel will no longer be handled in the containment at the Trojan facility. The possibility of a fuel handling accident in the spent fuel pool is remote due to the many administrative controls and physical limitations imposed on fuel handling operations. Nonetheless, a postulated fuel handling accident in the fuel building remains applicable and is the most limiting regarding the resulting radiation doses beyond the exclusion area boundary.

.1 The consequences of a postulated fuel handling accident at the Trojan facility are much lower than were previously analyzed for an operating reactor. Previous analyses required consideration of off-loading ofrecently irradiated fuel assemblies with large inventories of fission products.

Although almost nine months have elapsed since the last reactor operation, the consequences of this postulated accident have been reanalyzed conservatively assuming only a six month decay period since reactor operation. The analysis assumed that the fuel assembly with the highest radial flux peaking factor was damaged and that all fuel rods in the assembly were damaged. The fission product source and release assumptions ofRegulatory Guide 1.25, Rev. O were used in the analyses. The analysis assumed that all of the gap activity in the damaged rods was released to the spent fuel pool, consisting of 10 percent of the total noble gases other than Kr-85,30 percent of Kr-85 and I-129, and 10 percent of the remaining iodine in the rods. These assumptions are consistent with the current analyses in the SAR.

The I-129 inventory present in the peak assembly at the time of reactor shutdown was determined to be 16.6 millicuries. Thi: value was obtained by taking the total coreinventory of 1.943 Curies at shutdown, dividing by the total number of assemblies in the core to obtain an average assembly value, then multiplying by the radial peaking factor of 1.65. The amount ofI-129 available for release from the assembly was obtained by multiplying this value by the 30 percent gap fraction from Regulatory Guide 1.25. Assuming a pool iodine decontamination factor of 100, the result was an airborne release of 50 microcuries ofI-129. This results in a maximum unrestricted access I

location thyroid dose of 0.6 millirem.

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Trojan Nuclear Plam Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Page 6 of 41 The following table shows the results of the dose n:edel for the fuel handling accident as compared to the limits of 10 CFR 100. The calculated whole body and thyroid doses are a very small fraction of the limits of 10 CFR 100.

Exposure Exclusion Area Boundary 10 CFR 100 limits 4

Whole Body 0.5 x 10 Rem 25 Rem 4

Thyroid - Inhalation 0.6 x 10 Rem 300 Rem The calculated whole body dose at the intake of the control room ventilation system (CB-2) was 4

1.06 x 10 Rem. This is a very small fraction of the limit of 5 Rem contained in 10 CFR 50 Appendix A, General Design Criterion 19.

In addition to the fuel handling accident, the consequences of a loss of forced cooling to the spent fuel pool were also reanalyzed. The spent fuel pool is normally coo!ed by the spent fuel pool cooling system that was designed to maintain the water in the spent fuel pool at 140 F or less with the maximum number of fuel assemblies less one full core discharge. However, if forced cooling is lost, the design of the spent fuel pool provides an adequate heat sink through boiling and evaporation at the pool surface. The only requirement to ensure a sufficient heat sink for the spent fuel is the maintenance of the water level in the spent fuel pool such that the irradiated fuel assemb'ies remain covered.

The heat load in the spent fuel pool is much less than the design value due to the decay time that has elapsed since reactor shutdown and the number ofirradiated fuel assemblies stored in the pool. For this analysis the heat load was calculated at one year afler shutdown using the methodology of ANSI /ANS Standard 5.1-1979. This period is consistent with the expected implementation of this requested amendment. The analysis conservatively assumed a makeup water temperature of 100* F, no makeup provided before the onset of boiling and no evaporative losses during heatup. The spent fuel pool temperature before the loss of forced cooling was assumed to be 140* F. The following table shows the results of this analysis.

Loss of Spent Fuel Pool Forced Cooling Time After Shutdown 1 year -

Decay Heat Generated 1.05 megawatts Spent Fuel Pool Heatup Rate 1.68* F/hr Time to Boiling (140* F initial pool temp.)

43.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> Boil-ofTRate (no makeup) 7.5 gal / min Boil-off Rate (100* F makeup) 6.62 gal / min Time for Water Level to Lower to 10 Feet Above Irradiated Fuel 262 hours0.00303 days <br />0.0728 hours <br />4.332011e-4 weeks <br />9.9691e-5 months <br /> a

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Trojan Nuclear Plant Document Control Desk Decket 50-344 -

July 31,1993 License NPF-1 Attachment I Page 7 of 41 These results show that there is sufficient time to effect repairs to the cooling system or to establish makeup flow prior to uncovering the irradiated fuel. A number of sources of makeup to the spent fuel pool are available and methods of establishing makeup flow will be addressed in facility procedures.

i In summary, most of the accident scenarios described in SAR Section 15 are no longer possible due to the termination ofreactor operations and the removal of fuel from the reactor at the Trojan facility. The remaining postulated design bases accidents used in the development of these l

proposed PDTS are a fuel handling accident in the spent fuel pool and an extended loss of forced cooling to the spent fuel pool.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 l

License NPF-1 Attachment I

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Page 8 of 41 Description of Changes PGE reviewed each existing TTS to determine ifit should be retained in the PDTS in its present form, modified as appropriate for permanently defueled conditions, or deleted. The results of this evaluation are presented below on a section by section basis.

TTSSection 1 -Definitions Definitions are currently contained in Section 1.0 of the TTS. The TTS provides definitions for terminology that is unique to the technical specifications. These definitions are indicated i

throughout the text by showing the defined terms in all capital letters. This convention was retained in the improved Standard Technical Specifications and in the Trojan PDTS. However, with the reduction in scope of the PDTS as discussed in Section 2.0 and Sections 3/4 below, most of these terms are no longer applicable. For example, the definition of operational " modes" (TTS 1.4) are based on the conditions of the reactor and are no longer used. The following table shows a comparison of the existing TTS definitions with those contained in the improved standard technical specifications and the proposed PDTS.

Definitions TTS Section 1 Current TFS Improved STS Trojan PDTS-1.1 - Defined Terms 1.1 -- Definitions 1.1 - Definitions 1.2 - Thermal Power 1.1 - Definitions N/A 1.3 - Rated Thermal Power 1.1 - Definitions N/A 1.4 - Operational Mode or 1.1 - Definitions N/A Modes 1.5 - Action 1.1 - Definitions '

l.1 - Definitions l

1.6 - Operable - Operability 1.1 - Definitions N/A l

1.7 -- Reportable Event Not Included N/A 1.8 -- Containment Integrity Not Included N/A 1.9 - Channel Calibration 1.1 - Definitions N/A 1.10 - Channel Check 1.1 - Definitions N/A 1.11 ~- Channel Functional 1.1 - Definitions N/A Test 1.12 - Core Alteration 1.1 - Definitions N/A l

1.13 - Shutdown Margin 1.1 - Definitions N/A l

1.14 --Identified Leakage 1.1 - Definitions N/A 1.15 - Unidentified Leakage 1.1 - Definitions N/A l-

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 9 of 41 Definitions

'ITS Section 1 Current 'ITS Improved STS Trojan PDTS 1.16 -- Pressure Boundary 1.1 - Definitions N/A Leakage 1.17 - Controlled Leakage Not Included N/A 1.18 - Quadrant Power Tilt 1.1 - Definitions N/A Ratio 1.19 -- Dose Equivalent I-131 1.1 - Definitions N/A 1.20 - Staggered Test Basis 1.1 -- Definitions N/A 1.21 - Frequency Notation 1.4 - Frequency 1.4 -- Frequency 1.22 - Reactor Trip System 1.1 -- Definitions N/A Response Time 1.23 - Engineered Safety 1.1 - Definitions Feature Response N/A Time 1.24 - Axial Flux Difference 1.1 -- Definitions N/A 1.25 - Physics Tests 1.1 -- Definitions N/A 1.26 - Average 1.1 - Definitions N/A Disintegration Energy 1.27 -- Source Check.

Not Included N/A 1.28 - Process Control Program Included in Program Included in Program Section 5.7.2 Section 5.7.2 1.29 -- Solidification Not Included N/A 1.30 -- Offsite Dose Program Included in Program Included in Calculation Manual Section 5.7.2 Section 5.7.2 1.31 -- Gaseous Radwaste Not Included N/A Treatment System 1.32 -- Ventilation Exhaust Not Included N/A Treatment System 1.33 - Purging Not Included N/A 1.34 - Liquid Radwaste Not Included N/A Treatment System 1.35 - Core Operating Limits 1.1 -- Definitions N/A Report

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 l

License NPF-1 Attachment I Page 10 of 41 Definitions i

TFS Section 1 Current TTS Improved STS Trojan PDTS

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1.36 - Member (s) of the Not Included N/A Public i

As indicated in the table, most of the definitions of the current TTS are no longer applicable to the Trojan facility. The definition of" Action" has been retained in Section 1.1 of the PDTS and a new definition of" Certified Fuel Handler" has been added. The basis for the definition of a Certified Fuel Handler is discussed in more detail in the description of administrative controls.

Section 1 of the proposed PDTS also includes expanded information and examples related to the i

use oflogical connectors (Section 1.2), the interpretation of completion times (Section 1.3), and the interpretation of surveillance frequencies (Section 1.4). This expanded information is consistent with the improved standard technical specifications, and has been simplified as appropriate to the reduced scope and complexity of the proposed PDTS.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 i

License NPF-1 Attachment I Page11 of41 TTS Section 2 - Safzty Limits and Limiting Safety System Settings Section 2.0 of the TTS contains " safety limits" and " limiting system settings." In accordance with j

10 CFR 50.36(c)(1), safety limits are limits on parameters necessary to protect the physical i

barriers that guard against the uncontrolled release of radioactivity from a nuclear reactor. If a parameter exceeds the specified safety limit, the reactor must 've shutdown and operation may not.

resuene until authorized by the Commission.

Limiting safety system settings are values of various parameters associated with the nuclear steam supply system (NSSS) at which automatic protective action is needed during normal operations or

.j anticipated transients to prevent violation of the safety limits.

i Safety Limits and Limiting Safety System Settings TTS Section 2 i

i Current TTS Improved STS Proposed PDTS

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2.1.1 - Reactor Core 2.1.1 - Reactor Core N/A 2.1.2 - Reactor Coolant 2.1.2 - Reactor Coolant N/A J

System Pressure System Pressure 2.2.1 - Reactor Trip System 3.3.1 - Reactor Trip System Instrumentation Instrumentation N/A Setpoints Setpoints 1

The current TTS contain two safety limits. TTS 2.1.1 sets limitations on the combination of reactor thermal power, reactor coolant system pressure, and reactor coolant temperature. These limits prevent damage to the fuel cladding during reactor operation that could result in the release of fission products to the reactor coolant system. TTS 2.1.2 phces a limitation on the pressure in the reactor coolant system. This limitation prevents potential damage to the reactor coolant system pressure boundary that could result in the release of fission products in the reactor coolant system to the containment atmosphere.

The limiting safety system settings are contained in TTS 2.2.1. This specification establishes limits on the setpoints of the reactor protection system (RPS). The RPS monitors various parameters associated with reactor operation and initiates a shutdown of the reactor if the settings.

are exceeded during normal operation or anticipated operational occurrences. Examples of the parameters included within the scope of the RPS include reactor trips based on neutron flux, reactor coolant system temperature, pressurizer pressure, pressurizer water level, reactor coolant system flow rate, steam generator level, steam and feedwater flow, reactor coolant pump undervoltage or underfrequency, and various turbine trips.

The Trojan facility is permanently shutdown and fuel has been removed from the reactor vessel and placed in the spent fuel storage pool. The facility operating license has been revised to prohibit opuation of the facility as a nuclear reactor. Since no reactor is in operation at the Trojan facility and the license prohibits such operation in the future, TTSs 2.1.1 and 2.1.2 are no longer

Trojan Nuclear Plant Document Control Desk

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License NPF Attachment I Page 12 of41 applicable and are deleted in this proposed amendment. Since there is no longer an operating reactor at the Trojan facility, the functions of the RPS no longer serve a useful function and TTS 2.2.1 is also deleted in this proposed amendment.

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Trojen Nuclear Plant Document Control Desk i

Docket 50-344 July 31,1993 l

License NPF-1 Attachment I j

Page 13 of 41

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TTS Section 3M - Limiting Conditionsfor Operations and Surveillan. e Requirements In accordance with 10 CFR 50.36(e)(2), limiting conditions for operation (LCOs) specify the lowest functional capability or performance levels of equipment required for safe operation of the facility. The LCOs typically place restrictions on the availability of safety equipment needed to prevert or midgate a postulated DBA or on process variables necessary to preserve the initial conditions assumed in analyses n postulated design basis events. Associated surveillance requirements help to ensure that the specified equipment and parameters are maintained within the limits specified in the LCOs.

As discussed previously, only a limited set of postulated design basis accidents remains applicable to the Trojan facility in its permanently defueled state. As a result, most of the LCOs 'and accompanying surveillance requirements contained in the current TTS were determined to be inappropriate for retention in the proposed PDTS. The following table shows a comparison j

between the provisions of the current TTS, the corresponding sections of the improved standard -

technical specifications and the proposed PDTS. Each subsection of TTS Sections 3/4 is

-l discussed in more detail below.

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Limiting Conditions For Operation and Surveillance Requirements TTS Sections 3/4 Current TTS Improved STS -

Proposed PDTS j

3/4.0 - Applicability 3.0 - Limiting Condition for 3.0 - Limiting Condition for Operation Operation Applicability j

Applicability and and Surveillance Surveillance Requirement Requirement Applicability Applicability 3/4.1 -le. activity Control 3.1 - Reactivity Control N/A Systems Systems 3/4.2 - Power Distribution 3.2 -- Power Distribution N/A Limits Limits 3/4.3 - Instrumentation 3.3 -Instrumentation N/A 3/4.4 - Reactor Coolant 3.4 - Reactor Coolant N/A System System 3/4.5 - Emergency Core 3.5 - Emergency Core N/A Cooling System Cooling System 3/4.6 - Containment Systems 3.6 - Containment Systems N/A 3/4.7 - Plant Systems 3.7 - Plant Systems 3.1 - Defueled Systems (Selected LCOs) i 1

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Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 14 of 41 Limiting Conditions For Operation and Surveillance l

Requirements TFS Sections 3/4 1

Current TFS Improved STS Proposed PDTS 3/4.8 - Electrical Power 3.8 - Electrical Power N/A Systems Systems 3/4.9 - Refueling Operations 3.9 - Refueling Operations 3.1 - Defueled Systems

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(Selected LCOs) 3/4.10 - Special Test Not Included N/A Exceptions i

3/4.11 - Radioactive Not Included Deletion Pending per j

l Efiluents (Program Required by Previously Proposed License i

Section 5.7.2)

Amendment 1

l 3/4.12 -- Radiological Not Included Deletion Pending per Environmental (Program Required by Previously Proposed License Monitoring Section 5.7.2)

Amendment i

l TFS Section 3/4.0 - This section contains specifications that have generic applicability to the LCOs and surveillance requirements. Due to the limited number of LCOs remaining in the proposed PDTS and the relative simplicity of the rcquirements, a number of the TTS provisions in l

this section are no longer necessary for or applicable to the Trojan facility as indicated in the l

following table. The specifications that have not been retained in the proposed PDTS are discussed individually below.

Applicability L

TTS Sectious 3/4.0 Current TTS Improved STS Proposed PDTS 3.0.1 -- LCO. Applicability 3.0.1 - LCO Applicability 3.0.1 - LCO Applicability l

3.0.2 --Implementation of 3.0.2 - Implementation of 3.0.2 -- Implementation of LCO Actions LCO Actions LCO Actions 3.0.3 - Exceeding LCO 3.0.3 - Exceeding LCO N/A

- 3 l

Actions Actions j

L 3.0.4 -- Changes in Modes or 3.0.4 - Changes in Modes N/A Conditions or Conditions i

3.0.5 - Power Sources 3.0.6 - Support Systems N/A 1-l 1

i

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 15 of 41 Applicability TFS Sections 3/4.0 Current TFS Improved STS Proposed PDTS 4.0.1 - Applicability of SR 3.0.1 - Applicability of SR 3.0.1 -- Applicability of Surveillance Surveillance Surveillance Requirements Requirements Requirements 4.0.2 - 25% Extension of SR 3.0.2 -- 25% Extension SR 3.0.2 - 25% Extension Surveillance ofSurveillance ofSurveillance Frequencies Frequencies Frequencies 4.0.3 - Failure to Perform SR 3.0.3 -- Failure to SR 3.0.3 -- Failure to Surveillance Perform Perform Requirements Surveillance

' Surveillance Requirements Requirements 4.0.4 - Entry into SR 3.0.4 - Entry into Operational Modes or Operational N/A Conditions Modes or Conditions 4.0.5 -- ASME Code Class Program Included in 1,2, and 3 Section 5.7.2 N/A Components TTS Section 3.0.3 contains requirements to be implemented when an LCO and its associated action statements cannot be satisfied and the circumstances are not addressed in the LCO. TTS 3.0.3 requires a shutdown of the reactor under such conditions. TTS 3.0.3 is not applicable during plant modes 5 or 6. Since the Trojan facility no longer operates as a nuclear reactor, this specification would be meaningless in the PDTS and has not been retained.

TTS Section 3.0.4 contains restrictions on entry into an operational mode or specified condition when the LCO is not satisfied. The LCOs retained in the proposed PDTS are applicable whenever irradiated fuel is stored in the spent fuel pool. Therefore, this specification is not applicable and has not been retained in the proposed PDTS.

TTS Section 3.0.5 addresses the effect of the availability of emergency power sources on the operability of other equipment. As discussed in the following sections, the proposed LCOs in the PDTS do not cover operability of any electrically powered equipment. Therefore, this specification is not applicable and has not been retained in the proposed PDTS.

TTS Section 4.0.4 restricts entry into operational modes or conditions when surveillance requirements have not been met. The LCOs retained in the proposed PDTS are applicable-

t Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 16 of 41 whenever irradiated fuel is stored in the spent fuel pool. Therefore, this specification is not necessary and has not been retained in the proposed PDTS.

TTS Section 4.0.5 covers the inservice inspection and testing of ASME Code Class 1,2, and 3 Component 2 as required by 10 CFR 50.55a(g). By letter dated March 15,1993, PGE stated that 10 CFR 50.55a(g) and other related provisions are no longer applicable since the Trojan facility is no longer operated as a nuclear power reactor as specified in the regulation. Therefore, this specification is no longer applicable and has not been included in the proposed PDTS.

TTS Section 3/4.1 - TTS Section 3/4.1 contains LCOs and surveillance requirements related to control of reactivity in the reactor. This section contains LCOs related to the shutdown margin requirements of the reactor, limitations on the moderator temperature coefficient of the reactor, boration flow paths, etc. These provisions ensure that the reactivity of the nuclear reactor is such that it can be made subcritical at any time, that there will be no inadvertent criticality during shutdown conditions, and that the reactivity transients associated with postulated transients and accidents remain within acceptable limits. Since the reactor at the Trojan facility has been permanently shutdown and defueled, these specifications are no longer applicable and have been deleted. The specifications meet none of the screening criteria discussed under Background above.

TTS Section 3/4.2 Power Distribution Limits - These LCOs and Surveillance requirements restrict the allowable spatial distribution of nuclear and thermal power generation within the reactor core. LCOs in this section include limitations on axial flux difference, heat flux hot channel factor, nuclear enthalpy rise hot channel factor, quadrant power tilt ratio, and departure from nucleate boiling (DNB) parameters. These limitations ensure that the integrity of the fuel cladding is maintained during normal reactor operations and anticipated transients and that the i

initial conditions assumed in the analyses of postulated accidents affecting the reactor core remain valid. Since the reactor at the Trojan facility has been permanently shutdown and defueled, these specifications are no longer applicable and have been deleted. The specifications meet none of the screening criteria discussed above.

TFS Section 3/4.3 Instrumentation - This TfS section contains LCOs and surveillance requirements related to a wide variety ofinstrumentation systems. The follow

• g table lists the m

various specifications in this TTS section.

4 i

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 17 of 41 Limiting Conditions For Operation and Surveillance Requirements TTS Section 3/4.3 -Instrumentation Current TTS Improved STS Proposed PDTS 3/4.3.1 - Reactor Trip System 3.3.1 -- Reactor Trip Instrumentation System N/A Instrumentation 3/4.3.2 - Engineered Safety 3.3.2 - Engineered Safety Feature Actuation Feature Actuation N/A System System Instrumentation Instrumentation 3/4.3.3 - Monitoring Instmmentation 3/4.3.3.1 -- Radiation Not included N/A 3/4.3.3.2 -- Movable Incore Not Included N/A Detectors 3/4.3.3.3 - Seismic Not Included N/A 3/4.3.3.4 - Meteorological Not Included N/A 3/4.3.3.5 - Remote Shutdown 3.3.4 - Remote Shutdowm N/A System 3/4.3.3.6 - Chlorine 3.3.7 - Control Room N/A i

Emergency Filtration System Actuation Instrumentation 3/4.3.3.7 -- Fire Protection Not Included Deletion Pending per Previously Proposed License Amendment.

3/4.3.3.8 - Decouple Switches Not Included N/A i

3/4.3.3.9-- Accident 3.3.3 -- Post Accident

]

Monitoring Monitoring N/A Instmmentation Instrumentation 3/4.3.3.10 - Radioactive Not Included Deletion Pending per Liquid EfIluent Previously Proposed License Instrumentation Amendment.

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 18 of 41 Limiting Conditions For Operation and Surveillance Requirements TTS Section 3/4.3 - Instrumentation Current TFS Improved STS Proposed PDTS 3/4.3.3.11 - Radioactive Not Included Deletion Pending per Gaseous Effluent Previously Proposed License Instrumentation Amendment.

3/4.3.3.12 - SO Detection 3.3.7 - Control Room 2

System Emergency Filtration System N/A Actuation Instrumentation TTS 3/4.3.1 and 3/4.3.2 cover the instrumentation associated with the reactor trip system and the engineered safety features actuation system. These systems are designed to shutdown the reactor or initiate automatic protective actions when parameters exceed selected limits. The systems function to prevent or mitigate the consequences of postulated accidents that could result in damage to the reactor fuel cladding or the reactor coolant pressure boundary. Reactor operations have been terminated at the Trojan facility and the reactor has been permanently defueled.

Therefore, the postulated accident scenarios requiring actuation of these systems are no longer possible at the Trojan facility and these specifications have not been retained in the proposed PDTS.

TTS Section 3/4.3.3 covers a variety of monitoring instrumentation systems. These specifications are discussed separately below.

TTS 3/4.3.3.1 addresses radiation monitoring instrumentation installed in containment and in the area of the spent fuel storage area. The containment high range radiation monitors were installed in accordance with NUREG 0737, " Clarification of TMI Action Plans," to monitor post-accident containment gamma radiation levels up to 10' R/hr. Since the reactor has been permanently defueled and irradiated fuel is no longer present in the containment, these monitors are now unnecessary and have not been retained in the proposed PDTS. The Bases of the current TTS note that the LCO covering the spent fuel pool area radiation monitors is to ensure that "l) the radiation levels are continually measured in the areas served by the individual channels and 2) the alarm is initiated when the radiation level trip setpoint is exceeded." These radiation monitors will continue to serve this function during the permanently dcrueled status of the plant. However, this function does not satisfy the screening criteria for inclusion in the improved standard technical specifications or the modified criteria used for determining the scope of the PDTS. Specifically, the radiation monitors do not meet Criterion One since they do not serve to detect degradation of the integrity of the spent fuel pool. Criterion Two is not met since the radiation level in the area of the spent fuel pool is not an initial condition in the analyses of any DBA. Finally, Criterion

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993

)

License NPF-1 Attachment I Page 19 of 41 Three is not met since the radiation monitors do not function to prevent or mitigate a DBA that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

As noted in the SAR, these radiation monitors also serve as a criticality monitor. However, an inadvertent criticality is precluded by the design features of the spent fuel pool and storage racks and is not a DBA for the Trojan facility. Therefore, this specification has not been included in the proposed PDTS. This is consistent with the improved standard technical specifications contained i

in NUREG-1431.

TTS Section 3/4.3.3.2 contains LCOs and surveillance requirements for the moveable incore i

detectors. These detectors functioned to monitor the spatial distribution of neutron flux in the l

reactor core. Since the reactor has been shutdown and permanently defueled, these instruments no longer serve any function and have not been retained in the proposed PDTS.

TTS Section 3/4.3.3.3 contains LCOs and surveillance requirements for the seismic monitonng instrumentation. This instrumentation serves to measure the magnitude of a potential seismic i

event to aid in the evaluation ofits effect on facility structures. This function does not satisfy the screening criteria for inclusion in the improved standard technical speciScations or the modified criteria used for determining the scope of the PDTS. Specifically, the seismic monitors do not meet Criterion One since they do not serve to detect degradation of the integrity of the spent fuel 1

pool. Criterion Two is not met since the seismic monitors measure the magnitude of a seismic event but do not measure any initial condition assumed in the analyses. Finally, Criterion Three is not met since the seismic monitors do not function to prevent or mitigate any DBA. Therefore, this specification has not been included in the proposed PDTS. This is consistent with the improved standard technical specifications contained in NUREG-1431.

TTS Section 3/4.3.3.4 contains LCOs and surveillance requirements for the meteorological instrumentation. This instrumentation easures that suflicient meteorological data is available for 3

estimating potential radiation doses to the public as a result ofroutine or accidental release of j

radioactive materials to the atmosphere to allow evaluation of the need for protective measures to J

protect the health and safety of the public. However, as noted in the description of the revised 1

analyses discussed above, the limiting DBA no longer has the potential for producing radiation doses beyond the exclusion area boundary that would exceed the EPA evacuation protective action guidelines. The revised emergency plan for defueled conditions no longer requires this instrumentation. Further, this instrumentation does not meet the screening criteria for inclusion in the improved standard technical specifications or the modified criteria used for determining the scope of the PDTS. Specifically, the meteorological monitors do not meet Criterion One since they do not serve to detect degradation of the integrity of the spent fuel pool. Criterion Two is not met since the meteorological monitors do not measure initial conditions assumed in any design basis analyses. Finally, Criterion Three is not met since the meteorologica! monitors do not function to prevent or mitigate any DBA. Therefore, this specification has not been included in the proposed PDTS. This is consistent with the improved standard technical specifications contained in NUREG-1431.

TTS Section 3/4.3.3.5 contains LCOs and surveillance requirements for the remote shutdown instrumentation. This instrumentation ensures that sufficient capability is available to permit i

l Trojan Nuclear Plant Document Control Desk j

Docket 50-344 July 31,1993 j

License NPF-1 Attachment I Page 20 0f 41 shutdown of the reactor and maintenance of a safe shutdown condition if the control room becomes uninhabitable. Since the reactor at the Trojan facility has been permanently shutdown and defueled, this function is no longer required and this specification has not been retained in the PDTS.

TTS Sections 3/4.3.3.6 and 3/4.3.3.12 contain LCOs and surveillance requirements for the chlodne and SO detection instrumentation. This instrumentation is intended to promptly detect 2

and initiate protective action for control room personnel in the event of an accidental release of chlorine or SO. Liquid chlorine is no longer stored on-site. However, the potential for a toxic 2

gas release resulting from a nearby rail accident still exists. As noted in the discussion of the revised accident analyses, the only remaining design basis event requiring operator action is a prolonged loss of cooling to the spent fuel pool. Since the reanalysis of this postulated event shows that over ten days are available to restore cooling to the spent fuel pool or to initiate makeup flow, short term actions initiated from the control room are not necessary to protect the i

health and safety of the public. This instrumentation does not meet the screening criteria for inclusion in the improved standard technical specifications or the modified criteria used for determining the scope of the PDTS. Specifically, the chlorine and SO detectors do not meet 2

Criterion One since they do not serve to detect degradation of the integrity of the spent fuel pool.

Criterion Two is not met since the chlorine and SO detectors do not measure initial conditions 2

assumed in any design basis analyses. Finally, Criterion Three is not met since the chlorine and SO detectors do not function to prevent or mitigate any DBA. Therefore, this specification has 2

not been included in the proposed PDTS. This is consistent with the improved standard technical i

specifications contained in NUREG-1431.

TTS Section 3/4.3.3.7 contains LCOs and surveillance requirements for fire detection instrumentation. A pending license amendment request dated March 16,1993, has proposed deletion of this instrumentation from the TTS consistent with NRC guidance. Therefore, this instrumentation is not included in the proposed PDTS. This is consistent with the scope of the improved standard technical specifications.

]

TTS Section 3/4.3.3.8 contains LCOs and surveillance requirements for the decouple switches.

]

These switches ensure that the control cables passing through the cable spreading room to certain j

equipment needed for safe shutdown of the reactor will be isolated and local operation of the equipment can be achieved in the event of a fire in the cable spreading room. Since the reactor at the Trojan facility has been permanently shutdown and defueled, the functions of the safe shutdown equipment are no longer required and this specification has not been retained in the PDTS.

TTS Section 3/4.3.3.9 contains LCOs and surveillance requirements for accident monitoring instrumentation. This instrumentation is intended to provide information on selected plant parameters to monitor and assess variables during ar.d following an accident that causes damage to the reactor core and/or a breach of the reactor coolant pressure boundary. Since the reactor at the Trojan facility has been permanently shutdown and defueled, such postulated accidents are no

i Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 21 of 41 longer possible and the functions of this instrumentation are no longer required. This specification has not been retained in the PDTS.

TTS Sections 3/4.3.3.10 and 3/4.3.11 involve instrumentation for monitoring radioactive effluents. A pending license amendment request dated June 9,1993, has proposed deletion of i

these sections consistent with NRC guidance. Therefore, these sections have not been retained in the proposed PDTS. This is consistent with the scope of the improved standard technical specifications contained in NUREG-1431.

TTS Section 3/4.4 Reactor Coolant System - These LCOs and associated surveillance requirements are concerned with the protection of the reactor coolant pressure boundary and operation of the pressurizer and reactor coolant system pumps. The restrictions on the operation of reactor coolant pumps ensure that the DNB parameters in the reactor core remain within acceptable limits during power opeiation, while the restrictions on pressurizer safety and relief valves ensure the integrity of the pressure boundary. LCOs in this section on reactor coolant system chemistry, leakage, and pressure and temperature limits also address the integrity of the reactor coolant system boundary. LCOs covering the operation of the pressurizer and steam generators ensure the ability to remove heat generated by the reactor from the reactor coolant system. An LCO on the specific activity contained in the reactor coolant is also included in this section to ensure the assumptions ofinitial conditions for the analyses of off site dose consequences during a postulated steam generator tube rupture accident. Since the reactor at the l

Trojan facility has been permanently shutdown and defueled, the functions of the reactor coolant system are no longer required to prevent or mitigate the consequences of a postulated accident.

Therefore, these specifications are no longer applicable and have been deleted. The specifications meet none of the screening criteria discussed above.

TTS Section 3/4.5 Emergency Core Cooling System - These LCOs and associated surveillance requirements are concerned with the operation of various emergency core cooling systems. These j

systems include the accumulators, charging pumps, safety injection pumps, residual heat removal j

pumps and residual heat removal heat exchangers, associated valves, and the refueling water storage tank. The limitations on the operation of this equipment ensure that cooling can be provided to the reactor following a postulated loss of coolant accident. These specifications also ensure that the reactor coolant system will not be overpressurized during low temperature conditions. Since the reactor at the Trojan facility has been permanently shutdown and defueled, a loss of coolant from the reactor coolant system is no longer of concern and the reactor coolant system no longer serves any function to prevent or mitigate the consequences of any postulated accident. Therefore, these specifications are no longer applicable and have been deleted. These specifications meet none of the screening criteria discussed above.

i TTS Section 3/4.6 Containment Systems - These LCOs and associated surveillance requirements serve to ensure the integrity of the primary containment. The primary containment serves to limit the release of radioactive material to the environment in the event of postulated accidents that release radioactive materials from the reactor coolant system. Since the reactor at the Trojan facility has been permanently shutdown and defueled, there are no remaining postulated accidents which result in the release of radioactive materials to the containment.

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 22 of 41 Therefore, these specifications are no longer applicable and have been deleted. The specifications meet none of the screening criteria discussed above.

'ITS Section 3/4.7 Plant Systems - The plant systems section of the TTS covers a number of plant systems. The specifications contained in this section are listed in the table below and are discussed separately.

Limiting Conditions For Operation and Surveillance Requirements TTS Section 3/4.7 - Plant Systems Current 'ITS Improved STS Proposed PDTS 3/4.7.1 - Tmbine Cycle 3.7 - Various Sections N/A 3/4.7.2 - Steam Generator Pressure and Not Included N/A Temperature Limitation 3/4.7.3 - Component 3.7.7 - Component Cooling N/A Cooling Water Water System System 3/4.7.4 - Service Water 3.7.8 - Service Water N/A System System l

l 3/4.7.5 - Ultimate Heat Sink 3.7.9 - Ultimate Heat Sink N/A 3/4.7.6 - Control Room 3.7.10 - Control Room Emergency Emergency j

Ventilation System Filtration System N/A 3.7.11 - Control Room j

Emergency Air Temperature Control System 3/4.7.7 -- Sealed Source Not Included N/A Contamination 3/4.7.8 - Fire Suppression Not Included

'N/A Systems 3/4.7.9 - Penetration Fire Not Included N/A.

Barriers 3/4.7.10 - Snubbers Not Included N/A 3/4.7.11 - Control Building Modification Not Included N/A Connection Bolts l

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 23 of 41 TTS Sections 3/4.7.1 and 3/4.7.2 contain LCOs and surveillance requirements associated with the

[

turbine cycle and the steam generators. These systems functioned to remove heat from the reactor coolant system. Since the reactor has been shutdown and permanently defueled, these systems no longer serve any required function. Therefore these specifications have not been included in the proposed PDTS.

TTS Sections 3/4.7.3,3/4.7.4, and 3/4.7.5 cover the functions of the component cooling water system, the service water system, and the ultimate heat sink. The Bases for these TTS sections indicate these LCOs are intended to ensure that suflicient cooling capacity is available for continued operation of safety-related equipment during normal rezetor operation or accident conditions. These specifications also ensure that sufficient cooling capacity exists to provide for a normal cooldown or to mitigate the effects of a postulated accident involving the reactor. Since the reactor has been shutdown and permanently defucled, the active sruty-related equipment served by these cooling systems is no longer required to prevent or ratigate any postulated DBA.

Thejustification for the deletion of the equipment served by these r aoling systems is provided under the discussion of the applicable TTS section. Further, since Ihe facility is already shutdown, the capacity of the ultimate heat sink is also no longer required. A 4 noted in the discussion of the revised safety analyses, active cooling systems are not required fc cooling of the irradiated fuel in the spent fuel storage pool. The SAR notes that the service water system serves as a source of makeup water for the spent fuel pool and is designed to withstand the effects of a design basis earthquake. However, as noted in the discussion of the analyses of a potential loss of forced cooling to the spent fuel pool, an extended time (over ten days) is now available to establish makeup to the spent fuel pool following a loss of forced cooling before the water level is reduced to a level ten feet above the top of the irradiated fuel. This extended period provides ample time

' for actions to effect repairs to the cooling system or to establish alternative sources of makeup water to the spent fuel pool, Given the time available, specific restrictions on cooling water systems or sources of makeup are not necessary and the systems do not meet the screening criteria for inc!asion in the PDTS. Specifically, these cooling systems do not meet Criterion One since they do not serve to detect degradation of the integrity of the spent fuel pool. Criterion Two is not met since the systems do not involve initial conditior.s assumed in any design basis analyses. Finally, Criterion Three is not met since the system:, do not function to prevent or mitigate a DBA that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The service water system provides one source of makeup to the spent fuel pool following a prolonged loss of forced cooling. However, since an extended time is available before this event pret ents any challenge to the integrity of a fission product barrier and several other sources of makeup are available, the service water system in not considered to be required to function to prevent or mitigate this event. Therefore, these specifications have not been included in the proposed PDTS.

TTS Section 3/4.7.6 contains LCOs and surveillance requirements associated with the control room ventilation system. The control room ventilation system ensures that the control room temperature does not exceed the duty rating of equipment and instmmentation cooled by this system and ensures that the control room will remain habitable for personnel during and following credible accidents involving the release of radioactive materials or toxic gases. The continued opvation of equipment or instmmentation located in the control room is not required in the event

Trojan Nuclear Plent Document Control Desk l-

. Docket 50-344 July 31,1993 l

License NPF-1 Attachment I Page 24 of 41 L

of a loss of cooling to the spent fuel pool. This is demonstrated by the revised accident analyses q

j discussed above and the resulting limited number of parameters meeting the criteria for inclusion

-l l

in the proposed PDTS. The revised accident analyses also demonstrate that the potential radiation dose from the limiting DBA at the intake of the control room ventilation system is only a small fraction of the regulatory limits. Therefore, the control room ventilation system is not needed to limit the radiation dose to control room personnel. Liquid chlorine is no longer stored l

on-site. However, the potential for toxic gases resulting from a nearby rail accident still exists.

As noted in the discussion of the revised accident analyses, the only remaining design basis event requiring operator action is a prolonged loss of cooling to the spent fuel pool. Since the reanalysis of this postulated event shows that over ten days are available to restore cooling to the spent fuel pool or to initiate makeup flow, short term actions initiated from the control room are not necessary to protect the heaith and safety of the public. This system does not meet the screening criteria for inclusion in the improved standard technical specifications or the modified j

criteria used for determining the scope of the PDTS. Specifically, the control room ventilation system does not meet Criterion One since associated instrumentation does not serve to detect degradation of the integrity of the spent fuel pool. Criterion Two is not met since the control room ventilation system does not measure initial conditions assumed in any design basis analyses.

l l

Finally, Criterion Three is not met since the control room ventilation system does not function to I

prevent or mitigate any DDA. Therefore, this system no longer serves to prevent or mitigate any DBA and this specification has not been retained in the proposed PDTS.

TTS Section 3/4.7. 7 contains LCOs and surveillance requirements associated with sealed source contamination. The LCO was intended to ensure that radiation doses resulting from ingestion or inhalation of source material do not exceed allowable limits. This specification does not meet the screening criteria for inclusion in the improved standard technical specifications or the modified criteria used for determining the scope of the PDTS. Specifict.lly, the specification does not meet Criterion One since it does not involve instrumentation used to detect degradation of the integrity of the spent fuel pool. Criterion Two is not met since the specification does not involve initial conditions assumed in any design basis analyses. Finally, Criterion Three is not met since the specification does not involve the function of any equipment or structure needed to prevent or mitigate any DBA. Therefore, this specification has not been included in the proposed PDTS.

This is consistent with the improved standard technical specifications contained in NUREG-1431.

TTS Section 3/4.7.8 and 3/4.7.9 contain LCOs and surveillance requirements associated with fire suppression systems and penetration fire barriers. A pending license amendment request has proposed deletion of these provisions from the TTS consistent with NRC guidance. Thuefore, this instrumentation is not included in the proposed PDTS. Requirements for maintenance of a fire protection program have been included in the administrative controls section of the proposed PDTS as discussed later in this document. This is consistent with the scope of the improved.

standard technical specifications contained in NUREG-1431.

TTS Section 3/4.7.10 contains LCOs and surveillance requirements associated with snubbers.

Functional snubbers were required to ensure the structural integrity of the reactor coolant system and other safety-related systems following a seismic or other dynamic load. The reactor coolant system and other safety-related systems affected by this specification are no longer required for i

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 Licer.se NPF-1 Attachment I Page 25 of 41 the safe storage ofirradiated fuel. The basis for the deletion of these systems is provided in the discussion of the applicable TTS section. Therefore, this specification is not retained in the proposed PDTS.

TTS Section 3/4.7.11 contains LCOs &nd surveillance requirements associated with the control i

building modification connection boltr 'This specification is intended to maintain the structural adequacy of the modified control building consistent with the design as required to ensure the capability of the control-auxiliary-fuel building complex to withstand safely the operating basis earthquake and safe shutdown earthquake. The specification requires measurement of the tension in a sample of the bolts used to tie reinforced concrete and steel plate to the control building walls at six months, one, three and five years following installation and at five year intervals thereafter.

An initial installation tension design margin was incorporated to account for any potential bolt relaxation, creep of the concrete and grout, and shrinkage of concrete and grout. The surveillance program required by this specification is intended to ensure that this design margin is not significantly degraded. The results of swveillance of these bolts ihrough the first ten years have indicated no significant bolt degradation and show that the bolt tensions have stabilized and are not expected to decrease below the design margins in the future. This specification does tot meet the criteria for inclusion in the prc ased PDTS. Specifically, the specifetion does not meet Criterion One in that it does not inwolve instrumentation used to detect degradation of the integrity of the spent fuel pool. Criterion Two is not met since the specification does not involve any process variable that is an initial condition assumed in any design basis analyses. Finally, Criterion Three is not met since the specification does not involve any structure, system, or component that fur.ctions to prevent or mitigate a DBA that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Although the purpose of the bolts is to maintain the structural integrity of the control-auxiliary-fuel building complex during an operating basis and safe shutdown earthquake. '.hese design basis events do not assume the failure of or present a challenge to the integrity of the irradiated fuel cladding. Therefore, this speci ation has not been inck %I in the proposed PDTS. The control building bolts are a unique feature to the Trojan facility. However, the proposed PDTS are consistent with the improved standard "chnical specifications contained in NUREG-1431 in that the improved standard technical specifications do not include similar passive design features.

TTS Section 3/4.8 Electrical Power Systems - This TTS section contains LCOs and surveillance requirements associated with the AC and DC power sources and distribution systems.

The LCOs are intended to ensure that sufiicient power is available to supply the safety-related equipment required for the safe shutdown of the facility, the mitigation of accident conditions, and the monitoring of the facility status. The proposed PDTS do not contain LCOs for active safety systems. The limited set of remaining LCOs consists oflimitations on selected parameters associated with the storage ofirradiated fuel in the spent fuel pool (i.e., water level, boron concentration, and pool coolant temperature). These parameters are not subject to rapid change and do not require continuous monitoring. Since active safety systems are not contained in the proposed PDTS, the specifications covering electrical power to support such systems have not been retained in the proposed PDTS.

^

1 Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 26 of 41 TTS Section 3/4.9 Refueling Operations - This TTS section contains a number of

)

specifications related to refueling operations. Although refueling operations will no longer be i

conducted at the Trojan facility, a number of these specifications remain applicable to the storage ofirradiated fuel in the spent fuel pool and have been retained in the proposed PDTS. The specifications contained in this TTS section are listed in the following table and are discussed -

separately below.

Limiting Conditions For Operation and Surveillance Requirements TTS Section 3/4.9 - Refueling Operations t

Current TTS Improved STS Proposed PDTS 3/4.9.1 - Boron 3.9.1 - Boron Concentration Cor. centration (Reactor Coolant N/A System and Refueling Canal) 3/4.9.2 - Instrumentation 3.9.3 -- Neutron (Source Range Instrumentation N/A Neutron Flux) 3/4.9.3 - Decay Time Not Included N/A 3/4.9.4 - Containment 3.9.4 - Containment Building Penetrations N/A Penetrations q

3/4.9.5 - Communications Not Included N/A 3/4.9.6 - Manipulator Crane Not Includui N/A Operability 3/4.9.7 - Crane Travel - Fuel Not Incio'

< 1.4 - Sperst Fuel Pool Load Building Restrictions 3/4.9.8 - Coolant Circulation 3.9.5 - RRR & Coolant Circulation - High Water Level N/A 3.9.6 - RHR & Coolant Circulation - Low -

Water Level 3/4.9.9 - Containment 3.3.6 - Containment Purge Ventilation and Exhaust N/A Isolation System Isolation I

Instrumentation I

i i

t Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 27 of 41 i

Limiting Conditions For Operation and Surveillance Requirements

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TTS Section 3/4.9 - Refueling Operations Current TFS Improved STS Proposed PDTS 3/4.9.10 -- Water Level-3.9.7 - Refueling Cavity N/A Reactor Vessel Water Level 3/4.9.11 - Storage Pool 3.7.15 - Fuel Storage Pool 3.1.1 - Spent Fuel Pool Water i

Water Level Water Level Level 3/4.9.12 - Spent Fuel Pool 3.7.13 - Fuel Building Air N/A Exhaust System Cleanup System j

3/4.9.13 - Containment

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Purge Exhaust Not Included N/A System Operation TTS Section 3/4.9.1 sets limits on the soluble boron concentration in the reactor coolant system

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and refueling canal. The limits ensure that the reactor remains subcritical during core alterations and that a uniform boron concentration is maintained in the water volume connected to the reactor vessel. Since the reactor has been permanently defueled, this specification is no longer I

applicable to the Trojan facility and has not been retained in the proposed PDTS.

l TTS Section 3/4.9.2 contair.s requirements related to the source range neutron flux monitors.

This instrumentation is used to detect changes in the reactivity of the reactor core. Since the reactor has been permanently defueled, this specification is no longer applicable to the Trojan facility and has not been retained in the proposed PDTS.

TTS Section 3/4.9.3 specifies a minimum decay time prior to the movement ofirradiated fuel assemblies in the reactor pressure vessel. This decay time ensures that short-lived fission products are allowed to decay such that the remaining inventory of fission products in a fuel assembly is_

j consistent with the assumptions of the accident analyses for a fuel handling accident. Since the l

reactor has been permanently defueled and approximately nine months have elapsed since final reactor operation, this specification is no longer necessary to protect the initial conditions of any DBA. Therefore, this specification has not been retained in the proposed PDTS.

]

TTS Section 3/4.9.4 contains requirements related to the containment building penetrations.

These requirements ensure that radioactive materials released to the environment due to a 1

postulated fuel handling accident in the containment are limited. Since the reactor has been permanently defueled and irradiated fuel is no longer located in the containment, this specification is no longer applicable to the Trojan facility and has not been retained in the proposed PDTS.

l TTS Section 3/4.9.5 requires communications capability such that refueling station personnel can be informed of significant changes in the facility status or core reactivity conditions during core 9

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 28 of 41 alterations. Since the reactor has been permanently defueled, this specification is no longer applicable to the Trojan facility and has not been retained in the proposed PDTS.

TTS Section 3/4.9.6 contains limitations related to the operation of the manipulator crane during movement of fuel or control rods in the reactor core. The specification ensures that the core internals and pressure vessel are protected from excessive lifling force. Since the reactor has been permanently defueled, the manipulator crane will no longer be used for moving fuel or control rods in the reactor core and neither the core internals nor pressure vessel serve any function related to the storage ofirradiated fuel. Therefore, this specification is no longer applicable to the Trojan facility and has not been retained in the proposed PDTS.

TTS Section 3/4.9.7 limits the loads that may be carried over irradiated fuel assemblies in the spent fuel pool. These limitations ensure that no more than the contents of one fuel assembly will be released as a result of a fuel handling accident or load drop over the spent fuel pool. A fuel handling accident in the spent fuel pool remains a valid DBA for the Trojan facility. Therefore this specification has been retained in the proposed PDTS as 3.1.4 - Spent Fuel Pool Load Restrictions.

I TTS Section 3/4.9.8 contains LCOs and surveillance requirements related to the operation of the residual heat removal system to provide cooling to the fuel in the reactor vessel during refueling i

modes. Since the reactor has been permanently defueled, the residual heat removal system is no longer required to perform this function and this specification has not been retained in the proposed PDTS.

TTS Section 3/4.9.9 contains requirements related to the containment ventilation isolation system.

This system ensures that the containment ventilation system penetrations are isolated in the event of a release of radioactive materials in the containment. Since the reactor has been permanently defueled and irradiated fuel has been removed from the containment, there are no remaining sources of significant radiation release within the containment. Therefore, the containment '

ventilation isolation system is no longer required and this specification has not been retained in the proposed PDTS.

TTS Sections 3/4.9.10 and 3/4.9.11 limit the minimum water level in the refueling canal and the spent fuel pool respectively. The specified water level ensures that sufficient water depth is available to remove 99 percent of the iodine assumed to be released from a fuel assembly as a i

result of a fuel handling accident. Since the reactor has been permanently defueled, there is no longer a potential for a fuel handling event in the reactor and TTS 3/4.9.10 has not been retained

)

in the proposed PDTS. A potential fuel handling event in the spent fuel pool remains a valid DBA for the Trojan facility. Therefore the limitation on minimum water level in the spent fuel pool has been retained as PDTS 3.1.1. PDTS 3.1.1 requires that the spent fuel pool level be maintained within limits and requires verification of compliance at a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> frequency. The actions.

associated with this LCO require immediate suspension of movement ofirradiated fuel or other loads over storage racks containing irradiated fuel and the immediate initiatiou of makeup flow.

The LCO allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore the level to within limits. This period is appropriate since the immediate actions preclude a possible fuel handling accident and the extended time available i

Trojan Nuclear Plant Document Control Desk

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Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 29 of 41 before any adverse consequences result from a loss of normal cooling. The Bases for PDTS 3.1.1 have been expanded to include the function of the spent fuel pool coolant inventory in providing a heat sink for the irradiated fuel assemblies following a postulated prolonged loss of forced cooling.

TfS Section 3/4.9.12 contains LCOs and surveillance requirements related to the spent fuel pool exhaust system. This system provides filtration for radioactive material released from an irradiated fuel assembly as a result of a postulated fuel handling accident. However, as described in the discussion of revised accident analyses, the radioactive decay in the first six months following final operation of the reactor has reduced the fission product inventory in the irradiated fuel assemblies to a level that no longer requires cperation of this system. Analyses of a postulated fuel handling accident indicated that without credit for the operation of the spent fuel pool exhaust system, the radiation doses beyond the exclusion area boundary and at the intake of the control room ventilation system (CB-2) will be limited to a very small fraction of the regulatory limits. Therefore, operation of the spent fuel building exhaust system is no longer required to prevent or mitigate the consequences of a DBA and this specification has not been retained in the proposed PDTS.

TTS Section 3/4.9.13 contains requirements related to the containment purge / exhaust system.

These restrictions ensure that the off-site doses resulting from a postulated fuel handling accident

~i in the containment are within the bounds of the accident analyses. Since the reactor has been permanently defueled and irradiated fuel has been removed from the containment, a fuel handling event in the containment is no longer a potential DBA. Therefore, this specification has not been retained in the proposed PDTS.

TFS Section 3/4.10 Special Test Exceptions - This section provides for exceptions from various LCOs contained in TTS Section 3.1 -- Reactivity Control Systems; TFS Section 3.2 - Power Distribution Limits; and TTS Section 3.4 - Reactor Coolant System during I

physics testing. These tests are conducted to verify the design parameters of the nuclear reactor core after each refueling. TTS Sections 3.1,3.2, and 3.4 have not been retained in the proposed PDTS as discussed above. Further, since a reactor is no longer in operation at the Trojan facility, physics testing as provided for in TTS Section 3/4.10 will no longer be conducted. Therefore, the exceptions provided by this section are no longer necessary or appropriate and are not included in the proposed PDTS.

TFS Section 3/4.11 Radioactive Efiluents - A pending license amendment request dated June 9,1993, has proposed the deletion of these specifications from the TTS consistent with NRC guidance. Therefore, these specifications have not been included in the proposed PDTS.

However, the proposed PDTS (Section 5.7.2.4) do contain a requirement for maintenance of a radioactive effluent control program. This is consistent with the improved standard technical specifications contained in NUREG-1431.

TFS Section 3/4.12 Radiological Environmental Monitoring - A pending license amendment request has proposed the deletion of these specifications from the TTS consistent with NRC guidance. Therefore, these specifications have not been included in the proposed PDTS.

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 30 of 41 However, the proposed PDTS (Section 5.7.2.5) do contain a requirement for maintenance of a radiological environmental monitoring program. This is consistent with the improved standard technical specifications contained in NUREG-1431.

Additional Specification Included in the PDTS - Two LCOs that are not currently contained in the TTS were also identified as appropriate for the proposed PDTS. These specifications were determined to be necessary to meet Criterion Two, in that they cover limits that are initial conditions for design bases accidents. These specifications are discussed separately below.

t PDTS 3.1.2 places a limit on the minimum soluble boron concentration in the spent fuel pool.

The design of the spent fuel pool is based on the use of unborated water, which maintains a subcritical condition (kg 0.95) during normal operation with the spent fuel racks fully loaded.

However, the water in the spent fuel pool normally contains soluble boron. This results in large subcriticality margins under actual normal conditions. The presence of this soluble boron is credited in the analyses of abnormal conditions. Credit for soluble boron under abnormal or accident conditions is allowable since only a single accident need be considered at one time. Most accident conditions do not result in an increase in the reactivity of the spent fuel pool. However, the analyses performed to evaluate the effects of a postulated drop of an irradiated fuel assembly on the spent fuel racks assumed the presence of 2000 ppm soluble boron in the spent fuel pool water. The presence of soluble boron was also assumed in the evaluations of other abnormal events. The negative reactivity effect of the soluble boron compensates for any increased reactivity caused by postulated accident scenarios. The accident analyses are provided in the SAR and in PGE-1037, " Spent Fuel Storage Rack Replacement Report," dated July 1983.

PDTS 3.1.2 limits the boron concentration to no less than 2000 ppm to preserve the initial conditions assumed in the accident analyses. The LCO is applicable whenever irradiated fuel assemblies are stored in the spent fuel pool. When the concentration of boron in the spent fuel pool is less than required, the LCO requires immediate action to preclude the occurrence of an accident invohing the drop of an irradiated fuel assembly or other loads over storage racks containing irradiated fuel. The LCO actions also require that the boron concentration be restored within limits within 14 days. The most significant accident scenario for which the presence of boron is assumed is the drop of an irradiated fuel assembly over storage racks containing irradiated fuel. This postulated accident is precluded by the immediate actions. The probabilities i

of other accident scenarios affecting the reactivity of the spent fuel storage racks are of a much lower order of probability and the 14 day period allows a reasonable time to restore the boron concentration in the~ spent fuel pool to within limits.

The surveillance requirements verify that the concentration of boron in the spent fuel pool is within the required limit during the movement ofirradiated fuel assemblies or the movement of loads over storage racks containing irradiated fuel. As long as this condition is met, the analyzed accidents are fully addressed. The 7 day frequency is appropriate bec.c.ise no major replenishment of pool water that could result in a dilution of the boron concentration is expected to take place i

over such a short period. During periods of time when no activities invohing the movement of irradiated fuel assemblies or the movement ofloads over storage racks occurs, the surveillance frequency is decreased to 31 days. This frequency is appropriate since there is no potential for a i

l Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 31 of 41 fuel assembly drop or the other drop of a load over irradiated fuel assemblies. The frequency is appropriate since the potential for accidcuts affecting reactivity is much lower and no major replenishment of pool water that could result in a dilution of the boron concentration is expected to take place over such a period.

PDTS 3.1.3 limits the maximum spent fuel pool coolant temperature. As described in the discussion of the revised accident analyses for permanently defueled conditions, a forced cooling system is not necessary to provide an adequate heat sink for the irradiated fuel assemblies stored in the spent fuel pool. An adequate heat sink is provided as long as the fuel assemblies remain covered with water. However, should the spent fuel pool be allowed to heatup, the inventory of coolant in the pool will eventually begin to be reduced due to boiling and evaporation. Analyses show that over ten days are available before the water in the pool is reduced to a level ten feet above the top of the fuel assemblies. This is more than sufficient time to allow repairs of the forced cooling system or to establish a source of makeup flow to the pool (less than eight gallons per minute are required to offset evaporative losses). An initial pool temperature of 140 F is assumed in the analyses of a prolonged loss of forced cooling. Therefore, this parameter meets Criterion Two of the screening criteria and a limitation on this parameter is included in the proposed PDTS. This limitation ensures that actions are taken to maintain the initial conditions assumed in the analyses. The new LCO requires that immediate action be taken to initiate restoration of the pool temperature to within limits and to verify that a source of makeup water is available. Although over ten days are available to establish makeup flow, this early action is l

considered prudent to ensure that makeup water is available if required. Seven days are allowed to restore the temperature within limits. This period is considered appropriate since an elevated i

temperature above 140" F has a relatively small impact on the total time available to establish.

makeup flow to the spent fuel pool to ensure an adequate heat sink for cooling of the fuel assemblies. A surveillance requirement is included with this specification to verify that the spent fuel pool is within limits at a frequency of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Page 32 of 41 TTSSection 5-Design Features TTS Section 5.0 describes design features of the facility. In accordance with 10 CFR 50.36(c)(4),

this section describes features of the facility such as materials orconstruction or geometric l

arrangement that, if altered, would significantly affect safety and are not covered in other sections j

of the technical specifications.

The current TTS contain the design features in several areas. These specifications are listed m the table below with the corresponding sections of the improved standard technical specifications and the PDTS.

Design Features TFS Section 5 Current TFS Improved STS Trojan PDTS f.1 - Site 4.1 - Site 4.1 - Site 5.2 - Containment Not Included N/A 5.3 - Reactor Core 4.2 - Reactor Core N/A 5.4 - Reactor Coolant Not Included N/A System 1

5.5 - Emergency Core Not Included

-N/A Cooling System 5.6 - Fuel Storage 4.3 - Fuel Storage 4.2 - Fuel Storage j

5.7 - Seismic Classification Not Included N/A i

5.8 - Meteorological Tower Not Included N/A j

Location i

5.9 - Component Cyclic or Not Included N/A Transient Limit 1

Of these current sections, Section 5.1 describing the site and Section 5.6 describing spent fuel storage have been retained. These specifications are now located in PDTS Section 4.0 - Design

. Features in accordance with the numbering system in the improved standard technical -

specifications as PDTS 4.1 - Site and PDTS 4.2 - Fuel Storage.

1 The description of the site contained in PDTS 4.1 has been simplified and now consists of a description and figure showing the site and the exclusion area boundary. Figure 5.1-2 in the current TTS depicting the low population zone has been deleted.

1 The " low population zone" is defined in 10 CFR 100.3(b) as the area immediately surrounding the exclusion area which contains residents, the total number and density ofwhich are such that there is a reasonable probability that appropriate protective measures could be taken in their behalfin the event of a serious accident. This area was defmed in the TTS Section 5.1.2. By letter dated

i Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 33 of 41 March 9,1993, as supplemented by letter dated July 22,1993, Portland General Electric Company submitted proposed revisions to the Trojan Nuclear Plant Emergency Response Plan (Topical Report PGE-1008) which reduced the scope of the plan commensurate with the activities l

pertaining to maintaining the facility in a permanently defueled state. The permanently defueled status of the plant has eliminated the potential for many of the severe accident scenarios postulated in the SAR. The potential off-site doses due to the remaining applicable accident scenarios have been shown to result in potential radiation doses at the site boundary that are below the Environmental Protection Agency Evacuation Protective Action Guidelines. The low population zone is no longer used in the Permanently Defueled Emergency Plan. As such, the low population zone is no longer a significant design feature and the description of this boundary has been deleted in the proposed PDTS.

The current TTS section 5.1.3 describing flood control features has also been deleted. The i

Trojan facility yard elevation is located at 45 feet MSL. This elevation is considered safe from projected floods. Equipment necessary for the safe storage ofirradiated fuelis located above this level. The flood protection features covered by TTS 5.1.3 are described in SAR 2.4.2.2, 'Tiood Design Considerations." These features were intended to protect various pieces of equipment needed for safe shutdown of the reactor. The Trojan facility no longer operates as a nuclear power plant and has been permanently defueled. Therefore, these features are no longer necessary to protect equipment previously needed for safe shutdown of the reactor. These features are not necessary to ensure the safe storage ofirradiated fuel.

TTS Section 5.2 through 5.5 described the design features of the containment, reactor, reactor coolant system and engineered safety features. These structures and systems served to prevent or t

mitigate the consequences of postulated accidents involving the release of fission products in the containment. Since the Trojan facility is permanently shutdown and defueled, there is no longer the potential for accidents involving the release of fission products in the containment. Therefore these sections are not retained in the PDTS.

TTS Section 5.6 describes the design features of the facility related to the storage of new and irradiated fuel. Those portions of TTS Section 5.6 related to the storage ofirradiated fuel have i

been retained in PDTS Section 4.2. The provisions of the current TTS section related to the l

storage of new fuel have been deleted since the new fuel storage facilities are no longer used.

l i

TTS Section 5.7 describes the design features of the facility related to the capability to withstand a seismic event. The seismic design of the facility related to the storage ofirradiated fuel is described in the SAR. Consistent with the scope and content of the improved standard technical specifications, this information has not been retained in the PDTS.

TTS Section 5.8 describes the location ofmeteorological towers. This instrumentation provided meteorological information for use in estimating the potential consequences of radiological releases resulting from postulated accidents. By letter dated March 9,1993, as supplemented by -

1 letter dated July 22,1993, Portland General Electric Company submitted proposed revisions to the Trojan Nuclear Plant Emergency Response Plan (Topical Report PGE-1008) which reduced the scope of the plan conunensurate with the activities to be conducted pertaining to maintaining

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 34 of 41 the facility in a permanently defueled state. The permanently defueled status of the plant has eliminated the potential for many of the severe accident scenarios postulated in the SAR. The potential off-site doses due to the rema' ming applicable accident scenarios have been shown to result in potential radiation doses at the site boundary which are below the Environmental Protection Agency Evacuation Protective Action Guidelines. Therefore the meteorological instrumentation is no longer required by the Permanently Defueled Emergency Plan. As such, this section has not been retained in the PDTS and the meteorological towers are no longer depicted on Figure 5.1-1.

Section 5.9 describes the cyclic or transient limits imposed on various plant systems. These limits ensure that the systems or components included within the scope of the specification are operated within their design basis. The components included within the scope of the specification are delineated in TTS Table 5.9-1. These include the reactor coolant system and the secondary system. These systems are no longer in operation at the Trojan facility and do not affect the safe storage ofirradiated fuel. Therefore this section is not retained in the PDTS.

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Trojan Nuclear Plant Document Control Desk i

Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 35 of 41 TTSSection 6-Administrative Controls Consistent with the format of NUREG-1431, the administrative controls section is located in Section 5.0 of the proposed PDTS. Where practicable, the individual specifications in the proposed PDTS have also been patterned after those contained in the PDTS. Some desiations from the standard technical specifications have been included as appropriate to the unique status of the Trojan facility. The scope and complexity of activities, and consequently the size of the j

stafE at the Trojan facility is greatly reduced from those required for an operating power plant.

I Also, as demonstrated in the discussions above, the potential impact on the health and safety of.

i the public due to postulated accidents is much lower that at an operating power plant. Therefore, some administrative controls have been simplified as appropriate. The specific provisions of the current TTS are listed in the following table along with the corresponding sections of the

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improved standard technical specifications and proposed Trojan PDTS. These specifications are discussed separately below. The Trojan organization is currently in transition from an interim organizational structure to a long term structure appropriate for the permanently defueled status of the facility. Currentjob titles are listed in the proposed PDTS followed by the long term organization title in < >. This has been done to avoid the need for future license amendment requests solely to address title changes.

l Administrative Controls TTS Section 6 Current TTS Improved STS Trojan PDTS 6.1 -- Responsibility 5.1 -- Responsibility 5.1 - Responsibility 6.2 - Organizational 5.2 - Organization 5.2 - Organization 1

Requirements 6.3 - Facility Staff 5.3 - Unit Staff 5.3 - Facility Staff 1

Qualifications Qualifications Qualifications l

' 6.4 - Training 5.4 - Training 5.4 - Trauung 6.5 - Review and Audit 5.5 - Review and Audits -

5.5 - Review and Audits 6.6 - Reportable Event Not Included N/A Action l

6.7 - Safety Limit Violations 2.2 - SL Violations N/A-6.8 - Procedures and 5.7 - Procedures, 5.7 -- Procedures, Programs Programs Programs and and Manuals Manuals 6.9 - Reporting 5.9 - Reporting 5.8 - Reporting Requirements Requirements Requirements 6.10 - Record Retention 5.10 - Record Retention 5.9 - Record Retention

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 36 of 41 Administrative Controls TTS Section 6 Current TTS Improved STS Trojan PDTS I

6.11 - Radiation Protection 5.7.2.1 - Radiation 5.7.2.1 - Radiation Program Protection Protection Program Program 6.12 -- High Radiation Area 5.11 - High Radiation Area 5.10 -- High Radiation Area 6.13 -- Environmental Not Included N/A Qualification 6.14 - Process Control 5.7.2.2-Process Control 5.7.2.2 - Process Control Program Program Program l

6.15 - Off-site Dose 5.7.2.3-Off-site Dose 5.7.2.3 -- Off-site Dose Calculation Manual Calculation Calculation i

Manual Manual 6.16 - Major Changes to Radioactive Waste Not Included N/A Treatment Systems I

TTS Section 6.1 and 6.2 define the individual with overall responsibility for operation of the l

Trojan facility and other general organizational requirements. The content of these sections has been retained in PDTS 5.1 and 5.2. The PDTS sections are patterned after the format and J

wording of the improved standard technical specifications. However, the provisions of the current TTS that were recently incorporated by amendment no.191 to license NPF-1 to address the permanently defueled condition have been retained. The provision contained in the improved standard technical specifications relating to the annual designation of the person responsible for the operational command function has not been incorporated into the proposed PDTS._ The relatively small size and simplified structure of the Trojan facility staff make such a provision unnecessary. These unique provisions include the minimum shift crew composition and the requirements related to certified fuel handlers. The provisions of TTS 6.2.2.h stating that an operator holding a Senior Reactor Operator (SRO) license is qualified as a cutified fuel handler has been deleted as the SRO !icenses at the Trojan facility are no_ longer being maintained. The specific provisions related to the composition of the fire brigade has not been retained consistent with the scope of the improved standard technical specifications. Also in accordance with the improved standard technical specifications requirement for maintenance of a fire protection program has been included in PDTS 5.7.2.7.

TTS Section 6.3 specifies the requirements for qualifications of the facility staff. This specification has been retained without modification as PDTS 5.3.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 37 of 41 TTS Section 6.4 specifies the requirements for certified fuel handlers and the fire brigade. The requirements for training of certified fuel handlers have been retained without modification as proposed PDTS 5.4. The requirement for training of cenified fuel handlers has been retained per the current TTS. This provision was incorporated by amendment no.191 to license NPF-1 to address the permanently defueled status of the Trojan facility. Consistent with the improved standard technical specifications contained in NUREG-1431 the specific training requirements for the fire brigade are not specified in PDTS 5.4. However, also consistent with the improved standard technical specifications, a requirement for maintenance of a fire protection program has been included in PDTS 5.7.2.7.

i TTS Section 6.5 specifies the review and audit functions performed by the Plant Review Board (PRB) and the Trojan Nuclear Operations Board (TNOB). The review and audit functions of the PRB and the TNOB have been combined under the responsibility of a single review committee referred to in the proposed PDTS as the Independent Review and Audit Committee (IRAC).

With the termination of reactor operations at the Trojan facility and the conversion of the operating license to a possession only license, the scope and complexity of activities at the facility have been greatly reduced. Consequently, the permanent staff supporting the Trojan facility will also be much smaller than those required to support an operating power plant. The reduced scope of activities and limited staff make operation of two review committees impracticable and unnecessary. The responsibilities of the IRAC encompass the majority of the functions previously performed by the PRB and the TNOB. Selected functions have been modified consistent with the scope of activities at a permanently defueled facility.

TTS Section 6.6 covers requirements for events that are reportable per 10 CFR 50.73. Consisant with the content of the improved standard technical specifications, these provisions are not l

included in the proposed PDTS. The requirements for reponing of events are specified in the applicable regulations and additional detail is not necessary in the PDTS.

TTS Section 6.7 specifies the actions to be taken if a safety limit specified in TTS Section 2 is i

violated. As noted in the discussion of TTS Section 2.0 above, the safety limits are no longer applicable and have not been retained in the proposed PDTS. Therefore, the provisions of TTS Section 6.7 are unnecessary and have not been retained in the proposed PDTS, TTS Section 6.8 specifies requirements for procedures and programs. This specification has been retained, with appropriate modifications, as proposed PDTS 5.7. PDTS 5.7.1.1 covers the scope of required procedures. This section is consistent with the existing TTS and the improved standard technical specifications with the following exceptions. TTS 6.8.1.a covers procedures recommended in Appendix A ofRegulatory Guide 1.33, November 1972. This wording has been modified to clarify that only such procedures applicable to the safe storage ofirradiated fuel are included in this item (PDTS 5.7.1.1.a) and updated to reference Regulatory Guide 1.33, February 1978. TTS 6.8.1.b, refueling operations, has been deleted in the proposed PDTS since refueling operations will no longer be conducted at the Trojan facility. TTS 6,8.1.c conferring procedures for surveillance and test activities of safety-related equipment has also been deleted consistent with the scope of procedures included in the improved standard technical specifications. This provision is redundant to TTS 6.8.1.a which is included in the PDTS as noted above. TTS

Trojan N 2 clear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 38 of 41 Sections 6.8.2 and 6.8.3 cover permanent and temporary changes to procedures. The provisions of these sections have been retained as proposed PDTS 5.7.1.2 and 5.7.1.3. PDTS 5.7.1.2 has an added provision that changes to procedures be subject to an independent review. This provision was added since the IRAC is not required to review each procedure change as discussed above.

PDTS 5.7.1.3 covers temporary changes to procedures. The number of members of the facility management staff required to approve temporary changes to procedures has been reduced from two in the current TTS to one. This is consistent with the reduced scope and complexity of procedures required to support the permanently defueled facility and with the smaller management staff. TTS 6.8.3.c addressing PGE organizations other than the facility staff has been deleted since this distinction is no longer practicable with the reduced size of the organization.

TTS Section 6.8.4 addresses programs which are required to be maintained and implemented.

Program requirements are retained in the proposed PDTS 5.7.2. The existing programs addressed in TTS 6.8.4 are not applicable to a permanently defueled facility and have not been retained in the proposed PDTS. These include TTS 6.8.4.a, primary coolant sources outside containment; TTS 6.8.4.b, in-plant radiation monitoring; TTS 6.8.4.c, secondary water chemistry; and TTS 6.8.4.d, post-accident monitoring. The in-plant radiation monitoring program required by TTS 6.8.4.d provided for the monitoring of airborne iodine concentrations in vital areas under accident conditions. However, as demonstrated above, the limiting design basis accidents no longer have the potential for generating high radiation levels, and the need for short term access to specific plant areas to cope with vadous accident scenarios has been eliminated. Therefore, a specific in-plant radiation monitoring program is no longer necessary or appropriate.

The applicable programs included in the standard technical specifications have been incorporated in the proposed PDTS. These include PDTS 5.7.2.1, radiation control program; PDTS 5.7.2.2, process control program; PDTS 5.7.2.3, off-site dose calculation manual; PDTS 5.7.2.4, i

radioactive efIluent controls program; PDTS 5.7.2.5, radiological environmental monitoring program; PDTS 5.7.2.6, Storage Tank Radioactivity Monitoring Program; and PDTS 5.7.2.7, fire protection program. One additional program requirement for a spent fuel pool water chemistry program has been included in the proposed PDTS. This provision is not currently contained in the TTS or in the improved standard technical specifications. This program is similar to the secondary water chemistry program included in the standard technical specifications and is intended to provide controls to minimize any potential long term effects of corrosion on components in the spent fuel pool.

TTS Section 6.9 contains requirements for submitting various reports. This section has been j

retained, with appropriate modifications, as proposed PDTS 5.8. Several reports listed in TTS Section 6.9 are no longer appropriate for a permanently defueled facility and have been deleted in I

the proposed PDTS 5.8. These include:

• the results of steam generator tube inservice inspections required by TTS 6.9.1.5.b; documentation of challenges to the pressurizer power operated reliefvalves or safety valves required by TTS 6.9.1.5.c;

• results of specific activity analyses of the primary coolant required by TTS 6.9.1.5.d;

• startup repons required by TTS 6.9.1.1-3;

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 39 of 41 i

+ monthly operating reports required by TTS 6.9.1.6; q

+ and the core operating limits report required by TTS 6.9.1.7.

TTS Section 6.9.2 covering special reports has also been deleted since the referenced LCOs or surveillance sections have not been retained in the proposed PDTS.

1 The requirements for submittal of a semiannual radioactive emuent release report contained in TTS Sections 6.9.1.5.3 and 6.9.1.5.4 have also been deleted in the proposed PDTS. 10 CFR 20.106, " Radioactivity in effluents to unrestricted areas," sets limits on the release of radioactive effluents applicable to licensees of the NRC. For power reactors,10 CFR 50.36a, " Technical Specifications on effluents from nuclear power reactor," and 10 CFR 50 Appendix 1, " Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion 'As Low As Is Reasonably Achievable' for Radioactive Material in Light Water-Cooled Nuclear Power Reactor Efiluents," provide additional restrictions. The provisions of Appendix 1 are intended to ensure that the radioactive efiluents produced as a result of nuclear power reactor operations are processed and treated using the installed radioactive waste treatment systems to reduce the level of such effluents to the extent practicable. The principal source of such efiluents at nuclear power reactors are the continuous purification of the reactor coolant to remove radioactive materials resulting from the activation ofimpurities in the coolant or the leakage of fission products from the fuel rods during power operations. The provisions ofAppendix I are not appropriate for facilities other than nuclear power reactors as noted in Section I of Appendix I to 10 CFR 50. Since the reactor at the Trojan facility has been permanently shutdown and defueled, radioactive waste associated with reactor operations are no longer being produced. The levels of radioactive efiluents associated with the continued storage ofirradiated fuel are expected to be only a small fraction of those previously produced. Therefore, the administrative requirements associated with demonstrating compliance with the limits of Appendix I to 10 CFR 50 are no longer necessary or appropriate. Therefore, the requirement for a semiannual radioactive effluent report has not been retained in the proposed PDTS. As noted above, a new requirement has been included in the proposed PDTS (5.7.2.4) for the establishment of a

" Radioactive Effluent Controls Program." As stated in the PDTS 5.7.2.4, the purpose of this program is to provide appropriate controls to maintain the doses to members of the public from

r. dioactive effluents as low as reasonably achievable. This program requirement is consistent with the imoroved standard technical specifications except that provisions in the standard ~

technical specification explicitly related to compliance with Appendix I have been deleted and the -

frequency of the determination of cumulative and projected dose contributions from radioactive effluents has been reduced from monthly to quarterly (PDTS 5.7.4.d). This reduced frequency is consistent with the reduction in the magnitude of radioactive effluents associated with termination of reactor operations. As noted above, the proposed PDTS 5.7.2.5 also continues to provide for a " Radiological Environmental Monitoring Program." This program provides for monitoring of radionuclides in the environs of the plants to verify the accuracy of effluent monitoring and modeling of environmental exposure pathways.

1 The provision for inclusion of a Land Use Census in the radiological emironmental monitoring program as conta ned in the improved standard technical specifications has not been retained in i

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Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 40 of 41 the proposed PDTS. As noted in the bases for TTS 3.12.3, the purpose of this census is to satisfy the requirements of Section IV.B.3 of Appendix I to 10 CFR 50 by identifying the need for potential changes in the environmental monitoring program. As noted above, the magnitude of radioactive efiluents at the Trojan facility is much less than those associated with operation of a power reactor and the provisions of Appendix I are no longer applicable to the Trojan facility.

1 Therefore, a periodic land use census is no longer needed and has not been included in the proposed PDTS.

TTS Section 6.10 contains requirements for the retention of various types of records. This specification has been modified as appropriate and retained as PDTS 5.9. Consistent with the improved standard technical specifications, the retention period for licensee event reports, radioactive shipments and changes to specified procedures has been changed from five years to three years. Several record types have not been retained in the proposed PDTS as they are no longer applicable as demonstrated by the discussions of specific TTS sections. These include TTS 6.10.2.f covering records of transient or operational cycles, TTS 6.10.2.h covering records of inservice inspections, TTS 6.10.2.1 covering records of environmental qualification of electrical equipment and TTS 6.10.2.n covering records related to hydraulic and mechanical snubbers. TTS 6.I'.2.k covering records of review committee meetings has also been deleted from this section to i

0 be consistent with the format of the improved standard technical specifications, however, PDTS 5.9.3.h covers the records of review and audits required to be conducted by the review committee. The records of review committee meetings are also covered by PDTS 5.5.2. In addition, the wording of several items has been modified to clarify that the scope of the required records is limited to those activities affecting the safe storage ofirradiated fuel. With the exceptions noted the content of the proposed PDTS is consistent with the improved standard technical specifications contained in NUREG-1431.

TTS Section 6.11 specifies the requirement for a radiation protection program. This specification has been retained without modification as PDTS 5.7.2.1 and is consistent with the improved standard technical specifications contained in NUREG-1431.

TTS Section 6.12 specifies requirements for the control of high radiation areas. The provisions of this TTS section are included in proposed PDTS 5.10. Additional provisions contained in the improved standard technical specifications have also been included in this PDTS section. The scope and content ofPDTS 5.10 are consistent with the improved standard technical specifications contained in NUREG-1431.

TTS Section 6.13 specifies requirements related to the environmental qualification of safety-related electrical equipment. The environmental qualification requirements for safety-related electrical equipment require that equipment be shown capable of functioning in the harsh environments resulting from a loss of coolant accident or a rupture of a high-energy line.

Since the reactor at the Trojan facility has been permanently shutdown and defueled, the postulated accidents that could produce harsh emironments are no longer possible. It should also be noted that this TTS provision duplicates the requirements of 10 CFR 50.49 and similar provisions are not contained in the improved standard technical specifications ofNUREG-1431.

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment I Page 41 of 41 TTS Section 6.14 specifies requirements for a Process Control Program (PCP) covering the solidification of wet radioactive waste. These requirements have been incorporated into proposed PDTS 5.7.2.2. The wording of PDTS 5.7.2.2 is consistent with the improved standard technical specifications contained in NUREG-1431.

TTS Section 6.15 specifies requirements for an Off-site Dose Calculation Manual (ODCM) covering the methodology used in the calculation of off-site doses resulting from radioactive effluents. These requirements have been incorporated into proposed PDTS 5.7.2.3. The wording ofPDTS 5.7.2.3 is consistent with the improved standard technical specifications contained in NUREG-1431.

TTS Section 6.16 addresses major changes to radioactive waste treatment systems. A pending license amendment request dated June 9,1993, has proposed deletion of these sections consistent with NRC guidance. Therefore, these sections have not been retained in the proposed PDTS.

This is consistent with the scope of the improved standard technical specifications contained in NUREG-1431.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 1 of 50 No Significant Hazards Consideration Determination

Background

Portland General Electric (PGE) has permanently ceased power operation at the Trojan facility.

Subsequently PGE removed the fuel from the reactor vessel and placed it in storage in the spent i

fuel pool. The NRC has issued an amendment 190 to facility opera *ing license NPF-1, dated May 5,1993, removing the authority to operate the reactor and converting the former operating license to a possession only license. The termination of reactor operations of the Trojan Nuclear Plant and the conversion of the operating license to a possession only license has rendered many of the existing provisions of the technical specifications contained in Appendix A to the operating license moot or inappropriate. This proposed license amendment revises the current technical specifications to remove or modify the provisions as appropriate for the current facility status.

This proposed license amendment also revises the scope and content of the technical specifications to be consistent with NUREG-1431, " Standard Technical Specifications, i

Westinghouse Plants." The improved standard technical specifications contained in NUREG-1431 were developed to meet the goals and criteria set forth in the interim Commission Policy Statement for Nuclear Power Reactors, dated February 6,1987.

t The interim Commission Policy Statement established three criteria to define the scope of equipment and parameters included in the improved Technical Specifications. These criteria were developed for operating reacters and focused on instrumentation to detect degradation of the reactor coolant system pressure boundary and on equipment or process variables that affected the integrity of fission product barriers during design bases accidents or transients. PGE used l

slightly modified forms of the criteria, more appropriate for a permanently defueled facility, to ensure that equipment or process variables important to the safe storage ofirradiated fuel were -

not overlooked. PGE used these modified criteria to evaluate each existing technical specification to determine ifit should be retained in the PDTS.

j Criterion 1 of the interim Commission Policy Statement states that installed instrumentation used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary should be included in the technical specifications. Since no fuel is present in the reactor coolant system at the Trojan facility, this criterion is not applicable as originally written. PGE modified this criterion, however, to apply to installed instrumentation

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used to detect, and indicate in the control room, a significant abnormal degradation in the integrity of the spent fuel pool.

i Criterion 2 of the interim Commission Policy Statement states that process variables that are initial conditions of a Design Basis Accident (DBA) or transient analyses that either assume the

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failure of or present a challenge to the integrity of a fission product barrier should be incle 'ed in the technical specifications. This criterion remains applicable to a permanently defueled facility with the exception of the reference to transient analyses and this phrase was deleted in the criteria

-l used to develop the PDTS. The scope of DBAs applicable to a permanently defueled facility is '

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 2 of 50 also markedly reduced from those postulated for an operating plant. The scope of DB As applicable to the Trojan facility is discussed in more detail below.

Criterion 3 of the interim Commission Policy Statement states that structures, systems, or components that are part of the primary success path and which function or actuate to mitigate a Design Basis Accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier should be included in the technical specifications. This criterion also remains applicable to a permanently defueled facility with the exception of the reference to transients. The reference to transients was deleted in the criterion used to develop the PDTS. The qualifying phrase "., that is part of the primary success path and which functions or actuates to mitigate a Design Basis Accident.. was deleted in favor of a more general statement that structures, systems, or components that function to prevent or mitigate the specified DBAs should be included in the proposed PDTS. The scope of DBAs applicable to a permanently defueled facility is also markedly reduced from those postulated for an operating plant. The scope of DBAs applicable to the Trojan facility is discussed in more detail below.

Section 15 of the SAR describes the DBA scenarios that were applicable to the Trojan Nuclear Plant while it was licensed to operate at power. However, with the permanent shutdown of the Trojan Nuclear Plant and the conversion of the operating license to a possession only license, most of the accident scenarios postulated in the SAR are no longer possible. PGE is revising the SAR to reflect the current facility status.

The most severe postulated accidents for nuclear power plants involve damage to the nuclear j

reactor core and the release oflarge quantities of fission products to the reactor coolant system.

I The heat generated by the reactor is removed by the forced flow of water within the reactor j

coolant system (RCS). The RCS, operating at high temperatures and pressures, transfers this heat through the steam generator tubes to the secondary system. Many of the accident scenarios postulated in the S AR involve failures or malfunctions in these systems that could affect the j

reactor core. With the termination of reactor operations at the Trojan facility and the conversion i

of the operating license to a possession only license, such accidents are no longer possible. The j

reactor, RCS, and secondary system are no longer in operation. The irradiated fuel is now stored i

in the spent fuel pool and these systems serve no function related to the storage ofirradiated fuel in the spent fuel pool. Therefore, the postulated accidents involving failure or malfunction of these systems are no longer applicable. These include the following SAR Sections:

15.1 - Increase in Heat Removal by the Secondary System 15.2 - Decrease in Heat Removal by the Secondary System 15.3 - Decrease in Reactor Coolant System Flow Rate 15.4 -- Reactivity and Power Distribution Anomalies 15.5 - Increase in Reactor Coolant Inventory 15.6 - Decrease in Reactor Coolant Inventory 15.8 -- Anticipated Transients without SCRAM 15.9 -- Evaluation of Safety Analysis for Mixed Fuel Design Core and Increased Steam Generator Tube Plugging.

l Trojan Nuclear Plant Document Control Desk Dock.et 50-344 July 31,1993 License NPF-1 Attachment II Page 3 of 50 The postulated accidents described in SAR section 15.7, " Radioactive Release from a Subcomponent or System" involve the release of radioactive materials from systems other than the RCS and secondary system. This includes a leak or failure in the Radioactive Gas Waste System (Section 15.7.1); a leak due to failure of a liquid radioactive waste tank (Section 15.7.3) and a fuel handling accident (Section 15.7.4). These postulated events were not eliminated when reactor operations ceased. However, since the production of radioactive gases and liquids associated with reactor operation has ceased, radioactive decay has eliminated much of the i

inventory of such materials that existed at the time the reactor was permanently shutdown.

l Therefore the analyses currently contained in the SAR are overly conservative. The SAR is being revised to reflect the current facility status. The specific effects on the accident scenarios discussed in Section 15.7 are discussed in more detail below.

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SAR Section 15.7.1 provides an analysis of a postulated failure of the Waste Gas Decay Tanks (WGDTs). During reactor operations the WGDTs are used to store and p' rmit the decay of e

radioactive gases to prevent or reduce the normal release of radioactive materials to the atmosphere. The radioactive contents of the WGDTs are principally the noble gases krypton and xenon, the particulate daughters of some of the krypton and xenon isotopes, and trace quantities of halogens. These noble gases were generated from fission during operation of the reactor.

Since the reactor is permanently shutdown, such gases are no longer generated at the Trojan facility. Further, within six months after shutdown of the reactor, the gases in the WGDTs have decayed such that there remains in the system only a very small fraction of the inventory accumulated during power operation. Therefore, there is no possibility of a release from the WGDTs that would result in doses beyond the exclusion area that would exceed a small fraction i

of the limits of10 CFR 100.

SAR Section 15.7.3 provides an analysis of a postulated failure of the Chemical and Volume Control System (CVCS) holdup tank. The CVCS holdup tank failure in an operating reactor has the highest atmospheric release source in the CVCS due to its large volume and the fact that it contains reactor coolant covered by gas from the waste gas system. However, within six months after the reactor ceased operation, the radioactive materials available for release off-site have decayed sufficiently and/or have been vented such that the activity levels are bounded by the i

WGDT rupture discussed above. Liquid effluent stored in the tanks are contained such that they

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do not escape the auxiliary or fuel buildings. Therefore, the postu3ated rupture of the CVCS holdup tank would not result in doses beyond the exclusion boundary that would exceed a small fraction of the limits of 10 CFR 100.

SAR Section 15.7.4 discusses the design basis fuel handling accident. Fuel will no longer be handled in the containment. The possibility of a fuel handling accident in the spent fuel pool is remote due to the many administrative controls and physical limitations imposed on fuel handling operations. Nonetheless, a postulated fuel handling accident in the fuel building remains applicable and is the most limiting DBA with regard to the resulting radiation doses beyond the exclusion area boundary.

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 4 of 50 The consequences of a postulated fuel handling accident at the Trojan facility are much lower than I

were previously analyzed for an operating reactor. Previous analyses required consideration of off-loading of recently irradiated fuel assemblies with large inventories of fission products.

Although almost nine months have elapsed since the last reactor operation, the consequences of this postulated accident have been reanalyzed conservatively assuming only a six month decay period since reactor operation. The analysis assumed that the fuel assembly with the highest radial flux peaking factor was damaged and that all fuel rods in the assembly were damaged. The fission product source and release assumptions of Regulatory Guide 1.25, Rev. O were used in the analyses. Consistent with the current SAR analyses, all of the gap activity in the damaged rods was assumed to be released to the spent fuel pool, consisting of 10 percent of the total noble i

gases other than Kr-85,30 percent of Kr-85 and I-129, and 10 percent of the remaining iodine in j

the rods.

The I-129 inventory present in the peak assembly at the time of reactor shutdown was determined to be 16.6 millicuries. This value was obtained by taking the total core inventory of 1.943 Curies at shutdown, dividing by the total number of assemblies in the core to obtain an average assembly value, then multiplying by the radial peaking factor of 1.65. The amount ofI-129 available for release from the assembly was obtained by multiplying this value by the 30 percent gap fraction from Regulatory Guide 1.25. Assuming a pool iodine decontamination factor of 100, the result i

was an airborne release of 50 microcuries ofI-129 This results in a maximum unrestricted access location thyroid dose of 0.6 millirem.

The results of the dose model for the fuel handling accident as compared to the limits of 10 CFR

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100 are shown below.

Exposure Exclusion Area Boundary 10 CFR 100 limits Whole Body 0.5 x 10 Rem 25 Rem Thyroid -- Inhalation 0.6 x 10 Rem 300 Rem 1

i The calculated whole body dose at the intake of the control room ventilation system (CB-2) was l.06 x 10 Rem. This is a very small fraction of the limit of 5 Rem contained in 10 CFR 50 Appendix A, General Design Criterion 19. The calculated whole body and thyroid doses are also a very small fraction of the limits of 10 CFR 100.

Besides the fuel handling accident, the consequences of a loss of forced cooling to the spent fuel pool were also reanalyzed. The spent fuel pool is nonnally cooled by the spent fuel pool cooling :

system that was designed to maintain the water in the spent fuel pool at 140* F or less with the o tximum number of fuel assemblies less one full core discharge. However, in the event that forced cooling is lost, the spent fuel pool is designed to provide an adequate heat sink through boiling and evaporation at the pool surface. The only requirement to assure an adequate heat sink for the spent fuel is to maintain the water level in the spent fuel pool so that the spent fuel elements remain covered.

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Trojan Nuclear Plant Document Control Desk Docket 50-3F July 31,1993 License NPl..

Attachment II Page 5 of 50 The heat load in the spent fuel pool is much less than the design value due to the decay time that has elapsed since reactor shutdown and the number ofirradiated fuel assemblies stored in the pool. For this analysis the heat load was calculated at one year after shutdown using the methodology of ANSI /ANS Standard 5.1-1979. This period is consistent with the expected implementation of this requested amendment. The analysis conservatively assumed a makeup water temperature of 100* F, no makeup provided prior to boiling, and no evaporative losses occur during heatup. The spent fuel pool temperature prior to the loss of forced cooling was assumed to be 140* F. The results of this analysis indicate that over ten days are available from the initial loss of cooling until the water level in the pool is reduced to a level ten feet above the top of the irradiated fuel. The analysis also indicates that a makeup flow ofless than seven gallons per minute will offset the inventory losses due to boiling and evaporation. These results show that there is sufficient time to effect repairs to the cooling system or to establish makeup flow before uncovering the spent fuel. A number of sources of makeup to the spent fuel pool are available and methods ofestablishing makeup flow will be addressed in facility procedures.

In summary, most of the accident scenarios described in SAR Section 15 are no longer possible due to the termination of r"ctor operations and the removal of fuel from the reactor at the Trojan facility. The remaining postulated design bases accidents used in the development of these proposed PDTS are a fuel handling accident in the spent fuel pool and an extended loss of forced cooling to the spent fuel pool. The results of these design basis accidents were used in the evaluation of existing TTS provisions to determine if they were appropriate for inclusion in the proposed PDTS.

10 CFR 50.92(c) provides standards used by the NRC in determining whether a proposed license amendment involves a significant hazards consideration. A proposed amendment is deemed to involve no significant hazards consideration ifit meets the three standards set forth in the regulation. Following are evaluations of the specific proposed changes to the TTS using the standards of 50.92(c). As demonstrated by these evaluations, this proposed license amendment does not involve a significant hazards consideration.

Trojan Nuclear Plont Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 6 of 50 TTS 1.0- Definitions Definitions are provided in Section 1 of the TTS for terminology unique to the technical specifications. These defmed terms are indicated throughout the text of the technical specifications by showing the terms in all capital letters. This convernion was retained in the proposed PDTS. However, with the reduction in scope of the PDTS as discussed in the evaluation of the remaining TTS sections, most of these unique terms are no longer applicable.

For example, the definition of operational " modes" (TTS 1.4) are based on the conditions of the reactor and are no longer used in the permanently defueled condition of the Trojan facility. The definition of" Action" has been retained in Section 1.0 of the PDTS and a new definition of

" Certified Fuel Handler" has been added to the PDTS. The basis for the definition of a Certified Fuel Handler will be discussed in more detail in the description of administrative control Section 1 of the proposed PDTS also includes expanded information and examples related to the use of logical connectors (Section 1.2), the interpretation of completion times (Section 1.3), and the interpretation of surveillance frequencies (Section 1.4). This expanded information is consistent with the improved standard technical specifications, and has been simplified as appropriate to the reduced scope and complexity of the proposed PDTS.

Standard 1 - Operation of thefacility in accordance with theproposed amendment would not involve a significant increase in theprobability or consequences of an accidentpreviously evaluated The removal of the defined terms that no longer appear in the body of the proposed PDTS has no impact on facility structures or equipment or on the methods of operation of such structures or equipment. Further, the expanded explanatory information that has been added to this section consistent with the improved standard technical specifications adds to the clarity and ease of use of the proposed PDTS. Therefore, operation of the facility in accordance with the proposed changes to this TTS section do not involve any increase in the probability or consequences of any accident previously evaluated.

Standard 2 - Operation of thefacility in accordance with theproposed amendment would not create thepossibility ofa new or different kind of accidentfrom any accidentpreviously evaluated The removal of the defmed terms that no longer appear in the body of the proposed PDTS has no impact on facility structures or equipment or on the methods of operation of such structures or equipment. Further, the expanded explanatory information that has been added to this section consistent with the improved standard technical specifications adds to the clarity and ease of use of the proposed PDTS. Therefore, operation of the facility in accordance with the proposed changes to this TTS section would not create the possibility of a new or different kind of accident from any accident previously evaluated.

Standard 3 - Operation of thefacility in accordance with theproposed amendment would not involve a sigm*ficant reduction in a margin ofsafety.

The removal of the defined terms that no longer appear in the body of the proposed PDTS has no impact on facility structures or equipment or on the methods of operation of such structures or

4 Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 7 of 50 equipment. Further, the expanded explanatory information that has been added to this section

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consistent with the improved standard technical specifications adds to the clarity and ease of use of the proposed PDTS. Therefore, operation of the facility in accordance with the proposed changes to this TTS section would not involve any reduction in a margin of safety.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 8 of 50 TTS Section 2 - Safety Limits & Limiting Safety System Settings Section 2.0 of the TTS contains " safety limits" and " limiting system settings." In accordance with 10 CFR 50.36(c)(1), safety limits are limits on parameters necessary to protect the physical barriers that guard against the uncontrolled release of radioactivity from a nuclear reactor. If the

~l speciSed safety limits are violated, the reactor must be shutdown and operation may not resume until authorized by the Commission.

Limiting safety system settings are values of various parameters associated with the nuclear steam

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supply system (NSSS) at which automatic protective action is needed during normal operations or anticipated transients to prevent violation of the safety limits.

The current TTS contain two safety ilmits. TTS 2.1.1 sets limitations on the combination of reactor thermal power, reactor coolant system pressure, and reactor coolant temperature. These i

limits prevent damage to the fuel cladding during reactor operation that could result in the release of fission products to the reactor coolant system. TTS 2.1.2 places a limitation on the pressure in the reactor coolant system. This limitation is intended to prevent damage to the reactor coolant system pressure boundary that could result in the release of fission products in the reactor coolant system to the containment atmosphere.

The limiting safety system settings are contained in TTS 2.2.1. This specifbation establishes limits on the setpoints of the reactor protection system (RPS). The RPS monitors various parameters associated with reactor operation and initiates a shutdown of the reactor in the event j

that the settings are exceeded during normal operation or anticipated up. rational occurrences.

Examples of the parameters included within the scope of the RPS include reactor trips based on neutron flux, reactor coolant system temperature, pressurizer pressure, pressurizer water level, reactor coolant system flow rate, steam generator level, steam and feedwater flow, reactor coolant pump undervoltage or underfrequency, and various turbine trips.

j The Trojan facility is pennanently shutdown and fuel has been removed from the reactor vessel and placed in the spent fuel storage pool. The facility operating license has been revised to prohibit operation of the facility as a nuclear reactor. Since no reactor is in operation at the Trojan facility and the license prohibits such operation in the future, TTSs 2.1.1 and 2.1.2 are no longer applicable and are deleted in this proposed amendment. Since there is no longer an operating reactor at the Trojan facility, the functions of the RPS no longer serve a useful function and TTS 2.2.1 is also deleted in this proposed amendment.

Standard 1 - Operation of thefacility in accordance with theproposed amendment would not invoht a significant increase in theprobability or consequences ofan accidentpreviously evaluated.

The provisions of this section are solely related to the operation of the nuclear reactor. The postulated design basis accidents involving the reactor are no longer possible due to the permanently defueled status of the Trojan facility. The design basis accidents that remain applicable to the Trojan facility are not affected by these provisions. Therefore, operation of the e

Trojan Nuclear Plant Document ControlDesk Docket 50-344 July 31,1993 License NI'F-1 Attachment II Page 9 of 50 i

facility in accordance with the proposed changes to this TTS section does not involve any increare 1

in the probability or consequences of any accident previously evaluated.

Standard 2 - Operation ofthefacility in accordance with theproposed amendment would not create thepossibilite ofa new or dWerent kind ofaccidentfrom any accidentpreviously evaluated.

Tae provisions of this section are solely related to the operation of the nuclear reactor. The postulated design basis accidents invohing the reactor are no longer possible due to the permanently defueled status of the Trojan facility. The design basis accidents that remain applicable to the Trojan facility are not affected by these provisions. Therefore, operation of the facility in accordance with the proposed changes to this TTS section would not create the i

possibility of a new or different kind of accident from any accident previously evaluated.

Standard 3 - Operation of thefacility in accordance with theproposed amendment would not involve a significant reduction in a margin ofsafety.

The provisions of this section are solely related to the operation of the nuclear reactor. The postulated design basis accidents invohing the reactor are no longer possible due to the permanently defueled status of the Trojan facility. The design basis accidents that remain applicable to the Trojan facility are not affected by these provisions. Therefore, operation of the facility in accordance with the proposed changes to this TTS section would not involve a reduction in any margin of safety.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 10 of 50 TTSSection 3M.0- Applicability This section contains specifications that have generic applicability to the LCOs and surveillance requirements. Due to the limited number of LCOs remaining in the proposed PDTS and the relative simplicity of the requirements, a number of the TTS pr3 visions in this section arc no longer necessary for or applicable to the Trojan facility. The specifications that have not been retained in the proposed PDTS are discussed individually below.

TTS Section 3.0.3 contains requirements to be implemented when an LCO and its associated action statements cannot be satisfied and the circumstances are not addressed in the LCO. TTS 3.0.3 requires a shutdown of the reactor under such conditions. TTS 3.0.3 is not applicable during plant modes 5 or 6. Given that the Trojan facility no longer operates as a nuclear reactor, this specification would be meaningless in the PDTS and has not been retained.

TTS Section 3.0.4 contains restrictions on entry into an operational mode or specified conditior.

when the LCO is not satisfied. The LCOs retained in the proposed PDTS are applicable whenever irradiated fuel is stored in the spent fuel pool. Therefore, this specification is not applicable and has not been retained in the proposed PDTS.

f TTS Section 3.0.5 addresses the effect of the availability of emergency power sources on the operability of other equipment. As discussed in the following sections, the propos ed LCOs in the PDTS do not cover operability of any electrically powered equipment. Therefore, this specification is not applicable and has not been retained in the proposed PDTS.

TTS Section 4.0.4 restricts entry into operational modes or conditions when survei) lance j

requirements have not been met. The LCOs retained in the proposed PDTS are applicable l

whenever irradiated fuel is stored in the spent fuel pool. Therefore, this specification is not necessary and has not been retained in the proposed PDTS.

TTS Section 4.0.5 covers the inservice inspection and testing of ASME Code Class 1,2, and 3 j

Components as required by 10 CFR 50.55a(g). By letter dated March 15,1993, PGE stated that 10 CFR 50.55a(g) and other related provisions are no longer applicable since Trojan is no longer an operating nuclear power facility as specified in the regulation. Therefore, this specification is no longer applicable and has not been included in the proposed PDTS.

i Standard 1 - Operation ofthefacility in accordance with theproposed amendment uvuld not involve a significant increase in theprobability or consequences of an accidentpreviously evaluated.

The generic actions and surveillance requirements that are no longer applicable due to the simplified nature of the proposed PDTS have no impact on facility structures or equipment or on the methods of operation of such stmetures or equipment. Therefore, operation of the facility in accordance with the proposed changes to this TTS section do not involve any increase in the probability or consequences of any accident previously evaluated.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attaciunent II i

Page11 of50 Standard 2 - Operation ofthefacility in accordance with theproposed amendment would not create the possibility of a new or different kind of accidentfrom any accidentpreviously evaluated.

The generic actions and surveillance requirements that are no longer applicable due to the simplified nature of the proposed PDTS have no impact on facility structures or equipment or on the methods of operation of such structures or equipment. Therefore, operation of the facility in accordance with the proposed changes to this TTS section would not create the possibility of a new or different kind of accident from any accident previously evaluated.

Standard 3 - Operation ofthefacility in accordance with theproposed amendment would not involve a sigmficant reduction in a margin ofsafety.

The generic actions and surveillance requirements that are no longer applicable due to the i

simplified nature of the proposed PDTS have no impact on facility structures or equipment or on the methods of operation of such structures or equipment or on the results of any accident analyses. Therefore, operation of the facility in accordance with the proposed changes to this TTS section would not involve a reduction in any margin of safety.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 12 of 50 TTS Section 3M.1 - Reactivity Control Systems ITS Section 3H.2 - Power Distribution Limits TTS Section 3/4.1 contains LCOs and surveillance requirements related to control of reactivity in the reactor. This section contJus LCOs related to the shutdown margin requirements of the reactor, limitations on the moderator temperature coeflicient of the reactor, boration flow paths, etc. These provisions are intended to ensure that the reactivity of the nuclear reactor is such that it can be made subcritical at any time, that there will be no inadvertent criticality during shutdown conditions, and that the reactivity transients associated with postulated transients and accidents remair within acceptable limits. TTS Section 3/4.2 contains LCOs and surveillance requiremente related to power distribution limits that restrict the allowable spatial distribution of nuclear and thermal power generation within the reactor core. LCOs in this section include limitations on axial flux difference, heat flux hot channel factor, nuclear enthalpy rise hot channel fact ar, quadrant power tilt ratio, and departure from nucleate boiling (DNB) parameters. These limitations ensure that the integrity of the fuel cladding is maintained during normal reactor operatiom : nd anticipated transients, and that the initial conditions assumed in the analyses of postulateo accidents affecting the reactor core remain valid. Since the reactor at the Trojan facility has been permanently shutdown and defueled, these specifications are no longer applicable and have been deleted.

Standard 1 - Operation of thefacility in accordance with theproposed amendment would not involve a significant increase in theprobability or consequences of an accidentpreviously evaluated These specifications are solely related to the operation of the nuclear reactor. Since the reactor at t

the Trojan facility has been permanently shutdown end defueled, the previously evaluated accidents involving the reactor are no longer possible. Therefore, operation of the facility in accordance with the proposed changes to this TTS section do not involve any increase in the probability or consequences of any accident previously evaluated.

Standard 2 - Operation ofthefacility in accordance with theproposed amendment would not create thepossibility of a new or different kind ofaccidentfrom any accidentpreviously evaluated i

These specifications are solely related to the operation of the nuclear reactor. Since the reactor at the Trojan facility has been permanently shutdown and defueled, the previously evaluated accidents involving the reactor are no longer possible. The deletion of these specifications does not affect any structures or equipment necessary for the safe storage ofirradiated fuel in the spent fuel pool or alter any method of operation related to storage ofirradiated fuel. Therefore, operation of the facility in accordance with the proposed changes to this TTS section would not create the possibility of a new or different kind of accident from any accident previously l

evaluated.

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Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 13 of 50 i

Standard 3 - Operadon ofthefacility in accordance with theproposed amendment would not inndre a sigmpcant reduction in a margin ofsafety.

These specifications are solely related to the operation of the nuclear reactor. Since the reactor at l

the Trojan facility has been permanently shutdown and defueled, the previously' evaluated l

accidents involving the reactor are no longer possible. Therefore the deletion of these specifications has no impact on the analyses of postulated design basis accidents that remam applicable to the Trojan facility. Therefore, operation of the facility in accordance with the j

proposed changes to this TTS section would not involve a reduction in any margin of safety.

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i Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 14 of 50

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i TTSSection 3N.3 -Instrumentation This TTS section contains LCOs and suneillance requirements related to a wide variety of instmmentation systems. The various specifications in this TTS section are discussed below.

l TTS 3/4.3.3.1 and 3/4.3.2 cover the instrumentation associated with the reactor trip system and the engineered safety features system. These systems are designed to shutdown the reactor or initiate automatic protective actions when parameters exceed selected limits. The systems function to prevent or mitigate the consequences of postulated accidents that could result in damage to the reactor fuel cladding or the reactor coolant pressure boundary. The reactor operation has been terminated at the Trojan facility and the reactor has been permanently defueled. Therefore, the postulated accident scenarios requiring actuation of these systems are no longer possible at the Trojan facility and these specifications have not been retained in the proposed PDTS.

TTS 3/4.3.3.1 addresses radiation monitoring instrumentation installed in the containment and in the area of the spent fuel stomge area. The containment high range radiation monitors were installed in accordance with NUREG 0737, " Clarification ofTMI Action Plans," to monitor post-accident ' containment gamma radiation levels up to 10' R/hr. Since the reactor has been permanently defueled and in adiated fuel is no longer present in the containment, these monitors are no longer necessary and have not been retained in the proposed PDTS. The Bases of the l

current TTS note that the LCO covering the spent fuel pool area radiation monitors is to ensure that "l) the radiation levels are continually measured in the areas served by the individual channels and 2) the alarm is initiated when the radiation level trip setpoint is exceeded." These radiation monitors will continue to serve this function during the permanently defueled status of the plant.

However, this function does not satisfy the screening criteria for inclusion in the improved standard technical specifications or the modified criteria used for determining the scope of the PDTS. Specifically, the radiation monitors do not meet Criterion One since they do not serve to detect degradation of the integrity of the spent fuel pool. Criterion Two is not met since the radiation level in the area of the spent fuel pool is not an initial condition in the analyses of any DBA. Finally, Criterion Three is not met since the radiation monitors do not function to prevent or mitigate i DBA that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. As noted in the SAR, these radiation monitors also serve as a criticality monitor. However, an inadvertent criticality is precluded by the design features of the spent fuel pool and storage racks and is not a DB A for the Trojan facility. Therefore, this specification has not been included in the proposed PDTS. This is consistent with the improved standard technical specifications contained in NUREG-1431.

TTS Section 3/4.3.3.2 contains LCOs and surveillance requirements for the moveable incore detectors. These detectors fimctioned to monitor the spatial distribution of neutron flux in the reactor core. Since the reactor has been shutdown and permanently defueled, these instmments j

no longer serve any function and have not been retained in the proposed PDTS.

TTS Section 3/4.3.3.2 contains LCOs and surveillance requirements for the seismic monitoring instrumentation. This instrumentation serves to measure the magnitude of a potential seismic -

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Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment U Page 15 of 50 event to aid in the evaluation of the effect on facility structures. This function does not satisfy the screening criteria for inclusion in the improved standard technical specifications or the modified criteria used for determining the scope of the PDT3. Specifically, the seismic monitors do not meet Criterion One since they do not serve to detect degradation of the integrity of the spent fuel pool. Criterion Two is not met since the seismic monitors measure the magnitude of a seismic event but do not measure any initial condition assumed in the analyses. Finally, Criterion Three is not met since the seismic monitors do not function to prevent or mitigate any DBA. Therefore, this specification has not been included in the proposed PDTS. This is consistent with the improved standard technical specifications contained in NUREG-1431.

TTS Section 3/4.3.3.4 contains LCOs and surveillance requirements for the meteorological instrumentation. This instrumentation ensures that sufficient meteorological data is available for estimating potential radiation doses to the public as a result of routine or accidental release of radioactive materials to the atmosphere to allow evaluation of the need for protective measures to protect the health and safety of the public. However, as noted in the description of the revised analyses discussed above, the limiting DBA no longer has the potential for producing radiation doses beyond the exclusion area boundary that would exceed the EPA evacuation protective action guidelines. The revised emergency plan for defueled conditions no longer requires this instrumentation. Further, this instrumentation does not meet the screening criteria for inclusion in

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the improved standard technical specifications or the modified criteria used for determining the

• cope of the PDTS. Specifically, the meteorological monitors do not meet Criterion One since they do not serve to detect degradation of the integrity of the spent fuel pool. Criterion Two is not met since the meteorological monitors do not measure initial conditions assumed in any design basis analyses. Finally, Criterion Three is not met since the meteorological monitors do not function to prevent or mitigate any DBA. Therefore, this specification has not been included in the proposed PDTS. This is consistent with the improved standard technical specificat ons l

contained in NUREG-1431.

TTS Section 3/4.3.3.5 contains ICOs and surveillance requirements for the remote shutdown instramentation. This instrumentation ensures that sufficient capability is available to permit

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shutdown of the reactor and maintenance of a safe shutdown condition in the event that the control room becomes uninhabitable. Since the reactor at the Trojan facility has been permanently shutdown and defueled, this function is no longer required and this specification has not been retained in the PDTS.

TTS Sections 3/4.3.3.6 and 3/4.3.3.12 contain LCOs and surveillance requirements for the chlorine and SO detection instrumentation. This instrumentation is intended to promptly detect 2

and initiate protective action for control room personnel in the event of an accidental release of chlorine or SO. Liquid chlorine is no longer stored on-site. However, the potential for toxic 2

gases resulting from a nearby rail accident still exists. As noted in the discussion of the revised accident :nalyses, the only remaining design basis event requiring operator action is a prolonged loss of cooling to the spent fuel pool. Since the reanalysis of this postulated event shows that over ten days are available to restore cooling to the spent fuel pool or to initiate makeup flow, short term actions initiated from the control room are not necessary to protect the health and safety of the public. This instrumentation does not meet the screening criteria for inclusion in the I

Trojan Nucl=r Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 16 of 50 improved standard technical specifications or the modified criteria used for determining the scope of the PDTS. Specifically, the chlorine and SO, detectors do not meet Criterion One since they do not serve to detect degradation of the integrity of the spent fuel pool. Criterion Two is not met since the chlorine and SO detectors do not measure initial conditions assumed in any design 2

basis analyses. Finally, Criterion Three is not met since the chlorine and SO, detectors do not function to prevent or mitigate any DBA. Therefore, this specification has not been included in i

the proposed PDTS. This is consistent with the improved standard technical specifications contained in NUREG-1431.

TTS Section 3/4.3.3.7 contains LCOs and smveillance requirements for fire detection instrumentation. A pending license amendment dated March 16,1993, request has proposed deletion of this instrumentation from the TTS in accordance with NRC guidance. Therefore, this instrumentation is not included in the proposed PDTS. This is consistent with the scope of the improved standard technical specifications.

TTS Section 3/4.3.3.8 contains LCOs and surveillance requirements for the decouple switches.

These switches ensure that the control cables passing through the cable spreading room to certain equipuent needed for safe shutdown of the reactor will be isolated and local operation of the i

equipment can be achieved in the event of a fire in the cable spreading room. Since the reactor at the Trojan facility has been permanently shutdown and defueled, the functi~ons of the safe shutdown equipment are no longer required and this specification has not been retained in the PDTS.

TTS Section 3/4.3.3.9 contains LCOs and surveillance requirements for accident monitoring instrumentation. This instrumentation is intended to provide information on selected plant i

parameters to monitor and assess variables during and following an accident that causes damage to the reactor core and/or a breach of the reactor coolant pressure boundary. Since the reactor at the Trojan facility has been permanently shutdown and defueled, such postulated accidents are no longer possible and the functions of this instrumentation are no longer required. This specification has not been retained in the PDTS.

TTS Sections 3/4.3.3.10 and 3/4.3.11 deal with instrumentation for monitoring radioactive effluents. A pending license amendment request dated June 9,1993, has proposed deletion of these sections consistent with NRC guidance. Therefore, these sections have not been retained in the proposed PDTS. This is consistent with the scope of the improved standard technical specifications contained in NUREG-1431.

Standard 1 - Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

Most of the design basis accidents postulated in the SAR are no longer possible due to the permanently defueled status of the facility. The instrumentation covered by TTS Section 3.3 was reviewed and discussed above and found either to be unnecessary for the safe storage of irradiated fuel or not to satisfy the criteria established by the NRC for inclusion in the scope of

Trojan Nuclear Plant Document Control Desk Docket.50-344 July 31,1993 License NPF-1.

Attachment II Page 17 of 50 technical specifications modeled after the improved standard technical specifications of i

NUREG-1431. Specifically, this instmmentation in not necessary to monitor any potential degradation of the integrity of the spent fuel pool and is not needed to function to prevent or mitigate the consequences of any DBA remaining applicable to the Trojan facility. Therefore, operation of the facility in accordance with the proposed changes to this TTS section does not involve any increase in the probability or consequences of any accident previously evaluated.

Standard 2 - Operation of thefacility in accordance with the proposed amendment would not create thepossibility ofa new or different kind of accidentfrom any accidentpreviously evaluated.

The deletion of these provisions from the technical specifications does not involve any change to the structures or equipment or methods of operation affecting the safe storage ofirradiated fuel in the spent fuel pool or the analysis of any design bases accident remaining applicable to the Trojan facility. Therefore, operation of the facility in accordance with the proposed changes to this TTS section would not create the possibility of a new or different kind of accident from any accident previously evaluated.

f Standard 3 - Operation of thefacility in accordance with theproposed amendment would not involve a significant reduction in a margin ofsafety.

The deletion of these provisions from the technical specifications does not impact the assumptions or methodology assumed in the analyses of any design bases accident remaining applicable to the Trojan facility. Therefore, operatior of the facility in accordance with the proposed changes to this TTS section would not involve eduction in any margin of safety.

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 18 of 50 1TS Section 3N.4 - Reactor Coolant System TTS Section 3M.5 - Emergency Core Cooling System TTS Section 3H. 6 - Containment Systems TTS Section 3/4.4 contains LCOs and associated surveillance requirements concerned with the protection of the reactor coolant pressure boundary and operation of the pressurizer and reactor I

coolant system pumps. The restrictions on the operation of reactor coolant pumps ensure that the DNB parameters in the reactor core remain within acceptable limits during power operation, while the restrictions on pressure safety and relief valves ensure the integrity of the pressure boundary. LCOs in this section on reactor coolant system chemistry, leakage, and pressure and temperature limits also address the integrity of the reactor coolant system boundary. LCOs covering the operation of the pressurizer and steam generators ensure the ability to remove heat generated by the reactor from the reactor coolant system. An LCO on the specific activity contained in the reactor coolant is also included in this section to ensure the assumptions ofinitial conditions for the analyses of off site dose consequences during a postulated steam generator tube rupture accident.

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TTS Section 3/4.5 contains LCOs and associated surveillance requirements concerned with the operation of various emergency core cooling systems. These systems include the accumulators, charging pumps, safety injection pumps, residual heat removal pumps and residual heat removal I

heat exchangers, associated valves, and the refueling water storage tank. The limitations on the operation of this equipment ensure that cooling can be provided to the reactor in the event of a postulated loss of coolant accident and ensure that the reactor coolant system will not be overpressurized during low temperature conditions. Since the reactor at the Trojan facility has been permanently shutdown and defueled, a loss of coolant from the reactor coolant system is no longer of concern and the reactor coolant system no longer serves any function to prevent or j

i mitigate the consequences of any postulated accident.

i TTS Section 3/4.6 contains LCOs and associated surveillance requirements to ensere the integrity of the primary containment. The primary containment serves to limit the release of radioactive material to the environment in the event of postulated accidents that release radioactive materials from the reactor coolant system. Since the reactor at the Trojan facility has been shutdown and defueled permanently, there are no remaining postulated accidents which result in the release of radioactive materials to the containment. Therefore, these specifications are no longer applicable and have been deleted The specifications meet none of the screening criteria discussed above.

Standard 1 - Operation of thefacility in accordance with theproposed amendment would not involve a significant increase in theprobability or consequences ofan accidentpreviously evaluated.

The postulated accidents involving damage to the reactor core and the subsequent release of radioactive materials to the containment are no longer possible at the Trojan facility. These systems have no impact on any design basis accident involving the safe storage ofirradiated fuel i

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Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 19 of 50 I

m the spent fuel storage pool. Therefore, operation of the facility in accordance with the l

proposed changes to this TTS section do not involve any increase in the probability or consequences of any accident previously evaluated.

Standard 2 - Operation ofthefacility in accordance with theproposed amendment would not i

create the possibility of a new or different kind ofaccidentfrom any accidentpreviously evaluated.

i The deletion of these specifications does not involve any change in the structures or equipment necessary for the safe storage ofirradiated fuel or affect the methods of storing or handling j

irradiated fuel. Therefore, operation of the facility in accordance with the proposed changes to this TTS section would not create the possibility of a new or different kind of accident from any i

accident previously evaluated.

Standard 3 - Operation ofthefacility in accordance with theproposed amendment would not involve a sigmficant reduction in a margin ofsafety.

The systems affected by these specifications have no impact on the analyses of any postulated accident applicable to the Trojan facility in its permanently defueled state. Therefore, operation of l

the facility in accordance with the proposed changes to this TTS section would not involve a reduction in any margin of safety.

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Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 20 0f 50 TTSSection 3M. 7-Plant Systems 1

TTS Section 3N.8 - Electrical Power Systems This TTS section covers a number of plant systems. The specifications contained in this section are discussed below.

TTS Sections 3/4.7.1 and 3/4.7.2 contain LCOs and surveillance requirements associated with the turbine cycle and the steam generators. These systems functioned to remove heat from the reactor coolant system. Since the reactor has been shutdown and permanently defueled, these systems no longer serve any required function. Therefore these specifications have not been included in the proposed PDTS.

TTS Sections 3/4.7.3,3/4.7.4, and 3/4.7.5 cover the functions of the component cooling water system, the service water system, and the ultimate heat sink. The Bases for these TTS sections indicate these LCOs are to ensure that suflicient cooling capacity is available for continued operation of safety-related equipment during normal reactor operation or accident conditions.

These specifications also ensure that suflicient cooling capacity exists to provide for a normal cooldown or to mitigate the effects of a postulated accident involving the reactor. Since the reactor has been shutdown and permanently defueled, the active safety-related equipment served by these cooling systems is no longer required to mitigate any postulated design basis accident.

Thejustification for the deletion of the equipment served by these cooling systems is provided under the discussion of the applicable TTS section. Further, since the facility is already shutdown, the capacity of the ultimate heat sink is also no longer required. As noted in the discussion of the revised safety analyses, active cooling systems are not required for cooling of the irradiated fuel in the spent fuel storage pool. The SAR notes that the service water system serves as a source of makeup water for the spent fuel pool and is designed to withstand the effects of a design basis eanhquake. However, as noted in the discussion of the analyses of a potential loss of forced cooling to the spent fuel pool, an extended time (over ten days) is now available to establish makeup to the spent fuel pool following a loss of forced cooling before the water level reached ten feet above the top ofirradiated fuel. This extended period provides ample time for actions to i

effect repairs to the cooling system or to establish alternate sources of makeup water to the spent fuel pool. Given the extended time available, specific restrictions on cooling water systems or sources of makeup are not necessary and the systems do not meet the screening criteria for inclusion in the PDTS. Specifically, these cooling systems do not meet Criterion One since they do not serve to detect degradation of the integrity of the spent fuel pool. Criterion Two is not met since the systems do not involve initial conditions assumed in any design basis analyses.

Finally, Criterion Three is not met since the systems are not part of the primary success path and do not function or actuate to mitigate a Design Basis Accident that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The service water system provides one source of makeup to the spent fuel pool in the event of a loss of forced cooling.

However, since an extended time is available before this event presents any challenge to the integrity of a fission product barrier and the availability of other sources ofmakeup, the service i

. Trojan Nuclear Plant Document Control Desk-Docket 50-344 July 31,1993 -

1 License NPF-1 Attachment II Page 21 of 50 water system in not considered the primary success path in the mitigation of this event.

Therefore, these specifications have not been included in the proposed PDTS.

TTS Section 3/4.7.6 contains LCOs and surveillance requirements associated with the control room ventilation system. The control room ventilation system ensures that the control room temperature does not exceed the duty rating of equipment and instrumentation cooled by this system and ensures that the control room will remain habitable for personnel during and following credible accidents involving the release of radioactive materials or toxic gases. The continued operation of equipment or instrumentation located in the control room is not required in the event of a loss of cooling. This is demonstrated by the revised accident analyses discussed above and the resulting limited number of parameters meeting the criteria for inclusion in the proposed PDTS. The revised accident analyses also demonstrate that the potential radiation dose from the limiting design basis accident at the intake of the control room ventilation system is only a small fraction of the regulatory limits. Therefore, the control room ventilation system is not needed to limit the radiation dose to control room personnel. Liquid chlorine is no longer stored on-site.

However, the potential for toxic gases resulting from a nearby rail accident still exists. As noted in the discussion of the revised accident analyses, the only remaining design basis event requiring operator action is a prolonged loss of cooling to the spent fuel pool. Since the reanalysis of this postulated event shows that over ten days are available to restore cooling to the spent fuel pool or to initiate makeup flow, short term actions initiated from the control room are not necessary to protect the health and safety of the public. This system does not meet the screening criteria for inclusion in the improved standard technical specifications or the modified criteria used for determining the scope of the PDTS. Specifically, the control room ventilation system does not meet Criterion One since associated instrumentation does not serve to detect degradation of the integrity of the spent fuel pool. Criterion Two is not met since the control room ventilation system does not measure initial conditions assumed in any design basis analyses. Finally, Criterion Three is not met since the control room ventilation system does not function to prevent or mitigate any design basis accident. Therefore, this system no longer serves to prevent or mitigate any design buis accident and this specification has not been retained in the proposed PDTS.

J TTS Section 3/4.7.7 contains LCOs and surveillance requirements associated with sealed source contaminatbn. The LCO was intended to ensure that radiation doses in the event ofingestion or inhalation of source material do not exceed allowable limits. This specification does not meet the screening criteria for inclusion in the improved standard technical specifications or the modified criteria used for determining the scope of the PDTS. Specifically, the specification does not meet Criterion One since it does not involve instrumentation used to detect degradation of the integrity of the spent fuel pool. Criterion Two is not met since the specification does not involve initial conditions assumed in any design basis analyses. Finally, Criterion Three is not met since the specification does not involve the function of any equipment or structure needed to prevent or mitigate any DBA. Therefore, this' specification has not been included in the proposed PDTS.

This is consistent with the improved standard technical specifications contained in NUREG-1431.

TTS Section 3/4.7.8 and 3/4.7.9 contain LCOs and surveillance requirements associated with fire suppression systems and penetration fire barriers. A pending license amendment request has proposed deletion of these provisions from the TTS in accordance with NRC guidance.

Trojan Nuclear Plant Document Control Desk Docket 50-344 bly 31,1993 License NPF-1

.sttachment II Page 22 of 50 Therefore, this instrumentation is not included in the proposed PDTS. Requirements for maintenance of a fire protection program have been included in the administrative controls section of the proposed PDTS as discussed later in this document. This is consistent with the scope of the improved standard technical specifications contained in NUIEG-1431.

TTS Section 3/4.7.10 contains LCOs and surveillance requirements associated with snubbers.

Functional snubbers were required to ensure the structural integrity of the reactor coolant system and other safety-related systems following a seismic or other dynamic load. The reactor coolant system and other safety-related systems affected by this specification are no longer required for the safe storage ofirradiated fuel. The basis for the deletion of these systems is provided in the discussion of the applicable TTS section. Therefore, this specification is not retained in the proposed PDTS.

TTS Section 3/4.7.11 contains LCOs and surveillance requirements associated with the control building modification connection bolts. This specification is intended to maintain the stmetural adequacy of the modified control building consistent with the design as required to ensure the i

capability of the control-auxiliary-fuel building complex to withstand safely the operating basis j

earthquake and safe shutdown earthquake. The specification requires measurement of the tension in a sample of the bolts used to tie reinforced concrete and steel plate to the control building walls at six months, one, three and five years following installation and at five year intervals thereafter.

An initial installation tension design margin was incorporated to account for any potential bolt relaxation, creep of the concrete and grout, and shrinkage of concrete and grout. The surveillance L

program required by this specification is intended to ensure that this design margin is not significantly degraded. The results of surveillance of these bohs through the first ten years have indicated no significant bolt degradation and show that the bolt tensions have stabilized and are not expected to decrease below the design margins in the future. This specification does not meet the criteria for inclusion in the proposed PDTS. Specifically, the specification does not meet L

Criterion One in that it does not involve instrumentation used to detect degradation of the integrity of the spent fuel pool. Criterion Two is not met since the specification does not involve l

any process variable that is an initial condition assumed in any design basis analyses. Finally, Criterion Three is not met since the specification does not involve any structure, system, or component that functions to prevent or mitigate a DBA that either assumes the failure of or j

presents a challenge to the integrity of a fission product barrier. Although the purpose of the l-bolts is to maintain the structural integrity of the control-auxiliary-fuel building complex during an operating basis and safe shutdown earthquake, these design basis events do not assume the failure of or present a challenge to the integrity of the irradiated fuel cladding. Therefore, this specification has not been included in the proposed PDTS. The control building bolts are a l

unique feature to the Trojan fedlity. However, the proposed PDTS are consistent with the l

improved standard technical specifications contained in NUREG-1431 in that the improved standard technical specifications do not include any similar passive design features.

TTS 3/4.8 contains LCOs and surveillance requirements associated with the AC and DC power sources and distribution systems. The LCOs are intended to ensure that sufficient power is I

available to supply the safety-related equipment required for the safe shutdown of the facility, the mitigation of accident conditions, and the monitoring 'of the facility status. The proposed PDTS i

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Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 23 of 50 do not contain LCOs for active safety systems requiring electrical power. The limited set of remaining LCOs consists oflimitations on selected parameters associated with the storage of irradiated fuel in the spent fuel pool (i. e., water level, boron concentration, and pool coolant temperature). These parameters are not subject to rapid change and do not require continuous monitoring. Since active safety systems are not contained in the proposed PDTS, the speciScations covering electrical power to support such systems have not been retained in the proposed PDTS.

Standard 1 - Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

The systems covered in these technical specification sections were reviewed and evaluated as discussed above and found either to no longer be applicable to the Trojan facility in its permanently defueled state, or not to meet the criteria established by the NRC for inclusion in technical specifications modeled after the improved standard technical specifications contained in NUREG-1431. The cooling water systems contained in this section do provide a source of cooling and/or makeup water to the spent fuel pool. However, reanalysis of the effects of a prolonged loss of cooling and makeup flow to the spent fuel pool using conservative heat loads applicable one year after the shutdown of the reactor demonstrate that an extended time period is available to effect repairs or establish alternate sources of makeup flow in accordance with facility procedures. Therefore the continuous availability of such systems is no longer necessary and the deletion of these specifications from the technical specifications will not result in an increase in the consequences or the probability of a loss of cooling leading to uncovering of the irradiated fuel.

Reanalyses have also demonstrated that the function of the spent fuel pool exhaust system is no longer needed to limit the consequences of a postulated fuel handling accident. The effect of radioactive decay since the permanent shutdown of the reactor has reduced the consequences of this event to levels well below those previously analyzed. Therefore, operation of the facility in accordance with the proposed changes to this TTS section do not involve any increase in the probability or consequences of any accident previously evaluated.

Standard 2 - Operation ofthefacility in accordance with theproposed amendment would not create the possibility of a new or different kind of accidentfrom any accidentpreviously evaluated.

The deletion of the provisions of these TTS sections does not affect systems credited in the revised accident analyses for the permanently defueled operation of the Trojan facility. These changes will not result in any modification to structures or equipment needed for the safe storage ofirradiated fuel or affect the methods of handling or storing irradiated fuel. Therefore, operation of the facility in accordance with the proposed changes to this TTS section would not create the possibility of a new or different kind of accident from any accident previously evaluated.

Standard 3 - Operation of thefacility in accordance with theproposed amendm'ent would not involve a significant reduction in a margin ofsafety.

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 24 of 50 The deletion of the provisions of these TTS sections does not affect systems credited in the revised accident analyses for the permanently defueled operation of the Trojan facility. Therefore, operation of the facility in accordance with the proposed changes to this TTS section would not involve a reduction in any margin of safety.

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License NPF-1 Attachment II Page 25 of 50 1TS Section 3N.9 - Refueling Operations This TTS section contains a number of specifications related to refueling operations. Although refueling operations will no longer be conducted at the Trojan facility, a number of these specifications remain applicable to the storage ofirradiated fuel in the spent fuel pool and have l

been retained in the proposed PDTS. The specifications contained in this TTS section are I

discussed separately below.

l TTS Section 3/4.9.1 sets limits on the soluble boron concentration in the reactoi coolant system and refueling canal. The limits ensure that the reactor remains subcritical during core alterations and that a uniform boron concentration is maintained in the water volume connected to the i

reactor vessel. Since the reactor has been permanently defueled, this specification is no longer applicable to the Trojan facility and has not been retained in the proposed PDTS.

TTS Section 3/4.9.2 contains requirements related to the source range neutron flux monitors.

This instrumentation is used to detect changes in the reactivity of the reactor core. Since the reactor has been permanently defueled, this specification is no longer applicable to the. Trojan facility and has not been retained in the proposed PDTS.

i TTS Section 3/4.9.3 specifies a minimum decay time prior to the movement ofirradiated fuel assemblies in the reactor pressure vessel. This decay time ensures that short-lived fission products i

are allowed to decay such that the remaining inventory of fission products in a fhel assembly is consistent with the assumptions of the accident analyses for a fuel handling accident. Since the reactor has been permanently defueled and approximately nine months have elapsed since final reactor operation, this specification is no longer necessary to protect the initial conditions of any l

design basis accident. Therefore, this specification has not been retained in the proposed PDTS.

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TTS Section 3/4.9.4 contains requirements related to the containment building penetrations.

These requirements ensure that radioactive materials released to the environment due to a postulated fuel handling accident in the containment are limited. Since the reactor has been permanently defueled and irradiated fuel is no longer located in the containment, this specification i

is no longer applicable to the Trojan facility and has not been retained in the proposed PDTS.

TTS Section 3/4.9.5 requires communications capability such that refueling station personnel can be informed of significant changes in the facility status or core reactivity conditions during core alterations. Since the reactor has been permanently defueled, this specification is no longer i

applicable to the Trojan facility and has not been retained in the proposed PDTS.

TTS Section 3/4.9.6 contains limitations related to the operation of the manipulator crane during movement of fuel or control rods in the reactor core. The specification ensures that the core I

internals and pressure vessel are protected from excessive lifting force. Since the reactor has been permanently defueled, the manipulator crane will no longer be used for this purpose of moving fuel or control rods in the reactor core and neither the core internals nor pressure vessel serve any

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 26 of 50 function related to the storage ofirradiated fuel. Therefore, this specification is no longer applicable to the Trojan facility and has not been retained in the proposed PDTS.

TfS Section 3/4.9.7 places limitations on the loads that may be carried over irradiated fuel assemblies in the spent fuel pol. These limitations ensure that no more than the contents of one fuel assembly will be released as a result of a fuel handling accident or load drop over the spent fuel pool. A fuel handling accident in the spent fuel pool remains a valid design basis accident for the Trojan facility. Therefore this specification has been retained in the proposed PDTS as PDTS 3.1.4.

'ITS Section 3/4.9.8 contains LCOs and surveillance requirements related to the operation of the residual heat removal system to provide cooling to the fuel in the reactor vessel during refueling modes. Since the reactor has been permanently defueled, the residual heat removal system is no longer required to perform this function and this specification has not been retained in the proposed PDTS.

TTS Section 3/4.9.9 contains requirements related to the containment ventilation isolation system.

This system ensures that the containment ventilation system penetrations are isolated in the event of a release of radioactive materials in the containment. Since the reactor has been permanently defueled and irradiated fuel has been removed from the containment, there are no remaining sources of significant radiation release within the containment. Therefore, the containment ventilation isolation system is no longer required and this specification has.not been retained in the proposed PDTS.

TTS Sections 3/4.9.10 and 3/4.9.11 limit the minimum water level in the refueling canal and the spent fuel pool respectively. The specified water level ensures that sufficient water depth is available to remove 99 percent of the iodine assumed to be released from a fuel ' assembly as a result of a fuel handling accident. Since the reactor has been permanently defueled, there is no longer a potential for a fuel handling event in the reactor and TTS 3/4.9.10 has not been retained in the proposed PDTS. A potential fuel handling event in the spent fuel pool remains a valid design basis accident for the Trojan facility. Therefore the limitation on minimum water level in the spent fuel pool has been retained as PDTS 3.1.1. PDTS 3.1.1 requires that the spent fuel pool level be maintained within limits and requires verification of compliance at a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> frequency.

The actions associated with this LCO require immediate suspension of movement ofirradiated fuel or other loads over storage racks containing irradiated fuel and the immediate initiation of makeup flow. The LCO allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore the level to within limits. This period is appropriate since the immediate actions preclude a possible fuel handling accident and the extended time available prior to any adverse consequences resulting from a loss of normal cooling. The Bases for PDTS 3.1.1 have been expanded to include the function of the spent fuel i

pool coolant inventory in providing a heat sink for the irradiated fuel assemblies in the event of a i

loss of forced cooling.

TTS Section 3/4.9.12 contains LCOs and surveillance requirements related to the spent fuel pool exhaust system. This system provides filtration for radioactive material released from an irradWd fuel assembly as a result of a postulated fuel handling accident. However, as described

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 27 of 50 l

in the discussion ofrevised accident analyses, the radioactive decay in the first six months i

i following final operation of the reactor has reduced the fission product inventory in the irradiated fuel assemblies to a level that no longer requires operation of this system. Analysis of a postulated fuel handling accident indicated that without credit for the operation of the spent fuel pool exhaust system, the radiation doses beyond the exclusion area boundary and at the intake of i

the control room ventilation system (CB-2) will be limited to a very small fraction of the limits mandated by regulations. Therefore, operation of the spent fuel building exhaust system is no longer required to mitigate the consequences of a design basis accident and this specification has not been retained in the proposed PDTS.

TTS Section 3/4.9.13 contains requirements related to the containment purge / exhaust system.

These restrictions ensure that the off-site doses resulting from a postulated fuel handling accident in the containment are within the bounds of the accident analyses. Since the reactor has been permanently defueled and irradiated fuel has been removed from the containment, a fuel handling event in the containment is no longer a potential design basis accident. Therefore, this specification has not been retained in the proposed PDTS.

Standard 1 - Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

The provisions of this section have been evaluated as discussed above and either found to be no longer applicable to the Trojan facility or have been retained in the proposed PDTS as appropriate. The deleted specifications do not affect the storage ofirradiated fuel and do not involve any accident analyses remaining applicable to the Trojan facility. Therefore, operation of the facility in accordance with the proposed changes to this TTS section does not involve any increase in the probability or consequences of any accident previously evaluated.

Standard 2 - Operation of thefacility in accordance with theproposed amendment would not create the possibility of a new or different kind ofaccidentfrom any accidentpreviously evaluated.

The changes proposed in this section do not involve any changes to structures or systems necessary for the storage ofirradiated fuel or the prevention or mitigation of design basis accident s remaining applicable to the Trojan facility. Funher, these changes do not alter the methods of storage or handling ofirradiated fuel in the spent fuel pool. Therefore, operation of the facility in accordance with the proposed changes to this TTS section would not create the possibility of a new or different kind of accident from any accident previously evaluated.

Standard 3 - Operation ofthefacility in accordance with theproposed amendment would not involve a significant reduction in a margin ofsafety.

The provisions deleted from this TTS section do not affect the analyses of any design basis i

accident remaining applicable to the Trojan facility. Therefore, operation of the facility in

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment Il Page 28 of 50 accordance with the proposed changes to this TTS section would not involve a reduction in any margin of safety.

TTS Section 3N. IO - Special Test Exceptions TTS Section 3/4.10 Special Test Exceptions - This section provides for exceptions from various LCOs contained in TTS Section 3.1, Reactivity Control Systems; TTS Section 3.2, Power Distribution Limits; and TTS Section 3.4, Reactor Coolant System during physics testing. These tests are conducted to verify the design parameters of the nuclear reactor core after each refueling. TTS Sections 3.1,3.2 and 3.4 have not been retained in the proposed PDTS as discussed above. Further, since a reactor is no longer in operation at the Trojan facility, physics testing as provided for in TTS Section 3/4.10 will no longer be conducted. Therefore, the exceptions provided by this section are no longer necessary or appropriate and are not included in the proposed PDTS.

Standard 1 - Operation of thefacility in accordance with theproposed amendment would not involve a significant increase in theprobability or consequences of an accidentpreviously evaluated.

The exemptions provided by this specification are no longer necessary since the referenced specifications have been deleted asjustified in the evaluations of those sections. The deletion of i

this section is an administrative change for consistency with other proposed changes. Therefore, operation of the facility in accordance with the proposed changes to this TTS section does not involve any increase in the probability or consequences of any accident previously evaluated.

Standard 2 - Operation of thefacility in accordance with theproposed amendment would not create the possibility of a new or different kind of accidentfrom any accidentpreviously evaluated.

The exceptions provided by this specification are no longer necessary since the referenced specifications have been deleted asjustified in the evaluations of those sections. The acletion of this section is an administrative change for consistency with other proposed changes. Therefore, operation of the facility in accordance with the proposed changes to this TTS section would not create the possibility of a new or different kind of accident from any accident previously evaluated.

Standard 3 - Operation ofthefacility in accordance with theproposed amendment would not involve a sigmficant reduction in a margin ofsafety.

The exceptions provided by this specification are no longer necessary since the referenced specifications have been deleted asjustified in the evaluations of those sections. The deletion of this section is an administrative change for consistency with other proposed changes. Therefore, operation of the facility in accordance with the proposed changes to this TTS section would not involve a reduction in any margin of safety.

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II l

Page 29 of 50 TTS Section 3M.11 - Radioactive Effluents TTS Section 3M.12 - Radiological Environmental Monitoring These TFS sections were proposed for deletion by a pending license change request dated June 9, 1993. The basis for concluding that such deletion does not involve a significant hazards consideration is contained in that license amendment application.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment Il Page 30 of 50 L

TTSSection 5-Design Features TTS Section 5.0 describes design features of the facility. In accordance with 10 CFR 50.36(c)(4),

this section describes features of the facility such as materials of constmetion or geometric arrangement that, if altered, would luve a significant effect on safety and are not covered in other sections of the technical specifications.

The current TTS contain the design features in the following areas:

[

• 5.1 - Site t

+ 5.2 - Containment

• 5.3 - Reactor Core 5.4 - Reactor Coolant System

+

5.5 - Emergency Core Cooling System

+

5.6 -- Fuel Storage

+

+ 5.7 - Seismic Classification 5.8 -Meteorological Tower Location

+

5.9 - Component Cycle or Transient Limits.

+

Of these current sections, Section 5.1 describing the site and Section 5.6 describing spent fuel storage have been retained. These specifications are now located in Section 4.0 - Design Features in accordance with the numbering system in the improved standard technical specifications as PDTS 4.1 - Site and PDTS 4.2 -- Fuel Storage.

The description of the site contained in PDTS 4.1 has been simplified and now consists of a description and figure showing the site and the exclusion area boundary. Figure 5.1-2 in the current TTS depicting the low population zone has been deleted.

The " low population zone" is defined in 10 CFR 100.3(b) as the area immediately surrounding the exclusion area which contains residents, the total number and density of which are such that there is a reasonable probability that appropriate protective measures could be taken in their behalfin the event of a serious accident. This area was defined in the TTS Section 5.1.2 and Figure 5.1-2.

By letter dated March 9,1993, as supplemented by letter dated July 22,1993, Portland General Electric Company submitted proposed revisions to the Trojan Nuclear Plant Emergency Response i

Plan (Topical Report PGE-1008) which reduced the scope of the plan commensurate with the activities to be conducted pertaining to maintaining the facility in a permanently defueled state.

i The permanently defueled status of the plant has eliminated the potential for many of the severe accident scenarios postulated in the SAR. The potential off-site doses due to the remaining

)

applicable accident scenarios have been shown to result in potential radiation doses at the site boundary which are below the Environmental Protection Agency Evacuation Protective Action Guidelines. Therefore the low population zone is no longer used in the Permanently Defueled Emergency Plan. As such, the low population zone is no longer a significant design feature and the description of this boundary has been deleted in the proposed PDTS.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 -

July 31,1993 License NPF-1 Attachment II Page 31 of 50 The current TTS section 5.1.3 describing flood control features has also been deleted. The Trojan facility yard elevation is located at 45 feet MSL. This elevation is considered safe from projected floods. Equipment necessary for the safe storage ofirradiated fuelis located above this level. The flood protection features covered by TTS 5.1.3 are described in SAR 2.4.2.2, " Flood Design Considerations." These features were intended to protect various pieces of equipment needed for safe shutdown of the reactor. The Trojan facility no longer operates as a nuclear power p' ant and has been permanently defueled. Therefore, these features are no longer necessary to protect equipment previously needed for safe shutdown of the reactor. These features are not necessary to ensure the safe storage ofirradiated fuel.

TTS Section 5.2 through 5.5 described the design features of the containment, reactor, reactor coolant system and engineered safety features. These structures and systems served to prevent or mitigate the consequences of postulated accidents involving the release of fission products in the containment. Since the Trojar facility is permanently shutdown and defueled, there is no longer the potential for accidents involving the release of fission products in the containment. Therefore these sections are not retained in the PDTS.

TTS Section 5.6 describes the design features of the facility related to the storage of new and irradiated fuel. Those portions ofTTS Section 5.6 related to the storage ofirradiated fuel have been retained in PDTS Section 4.2. The provisions of the current TTS section related to the storage of new fuel have been deleted since the new fuel storage facilities are no longer used.

TTS Section 5.7 describes the design features of the facility related to the capability to withstand a seismic event. The seismic design features of the facility related to the safe storage ofirradiated l

fuel are described in the SAR. Consistent with the scope and content of the improved standard technical specifications, this information has not been retained in the PDTS.

TTS Section 5.8 describes the location of meteorological towers. This instrumentation provided meteorological information for use in estimating the potential consequences of radiological releases resulting from postulated accidents. By letter dated March 9,1993, as supplemented by letter dated July 22,1993, Portland General Electric Company submitted proposed revisions to the Trojan Nuclear Plant Emergency Response Plan (Topical Report PGE-1008) which re41uced the scope of the plan commensurate with the activities to be conducted pertaining to maintaining the facility in a permanently defueled state. The permanently defueled status of the plant has eliminated the potential for many of the severe accident scenarios postulated in the SAR. The i

potential off-site doses due to the remaining applicable accident scenarios have been shown to result in potential radiation doses at the site boundary which are below the Erwironmental Protection Agency Evacuation Protective Action Guidelines. Therefore he meteorological instmmentation is no longer required by the Permanently Defueled Emergency Plan. As such, this section has not been retained in the PDTS and the meteorological towers are no longer depicted on Figure 5.1-1.

.J Section 5.9 describes the cyclic or transient limits imposed on various plant systems. These limits i

ensured that the systems or components included within the scope of the specification were operated within their design basis. The components included within the scope of the specification

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Trojan Nuclear Plant Document Control Desk i

Docket 50-344 July 31,1993 License NPF-1 Attachment Il Page 32 of 50 are delineated in TTS Table 5.9-1. These include the reactor coolant system and the secondary system. These systems are no longer in operation at the Trojan facility and do not affect the safe storage ofirradiated fuel. Therefore this section is not retained in the PDTS.

Standard 1 - Operation of thefacility in accordance with the proposed amendment would not involve a sigmpcant increase in theprobability or consequences ofan accidentpreviously evaluated.

The proposed deletion of the description of design features no applicable to the operation of the Trojan facility has no impact on the probability or consequences oi the remaining applicable design basis accidents. The deletion of the description of design features related to the seismic design of the facility is consistent with the scope of the improved standard technical specifications.

The seismic design features affecting the safe storage ofirradiated fuel will continue to be described in the SAR. Therefore, operation of the facility in accordance with the proposed changes to this TTS section does not involve any increase in the probability or consequences of any accident previously evaluated.

i Standard 2 - Operation of thefacility in accordance with the proposed amendment would not create thepossibility ofa new or different kind ofaccidentfrom any accidentpreviously evaluated.

The changes to this section do not involve changes to any structure or equipment affecting the safe stenge ofirradiated fuel or the methods of handling or storing such fuel. Therefore, operation of the facility in accordance with the proposed changes to this TTS section would not 1

create the possibility of a new or different kind of accident from any accident previously evaluated.

Standard 3 - Operation ofthefacility in accordance with theproposed amendment would not involve a sigmpcant reduction in a margin ofsafety.

The deletion of the description of design features which are not related to the storage ofirradiated fuel or which are inconsistent with the scope of the improved standard technical sr>ecifications of NUREG-1431, will not affect the analyses of the design basis accidents remaining applicable to the Trojan facility. Therefore, operation of the facility in accordance with the proposed changes to this TTS section would not involve a reduction in any margin of safety.

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 33 of 50 TTSSection 6-Administrative Controls i

Consistent with the format of NUREG-1431, the administrative controls section is located in Section 5.0 of the proposed PDTS, Where practicable, the individual specifications in the proposed PDTS have also been patterned after those contained in the NUREG-1431. Some deviations from the standard technical specifications have been included as appropriate to the unique status of the Trojan facility. The scope and complexity of activities, and consequently the size of the stafE at the Trojan facility are greatly reduced from those required for an operating power plant. Also, as demonstrated in the discussions above, the potential impact on the health r

and safety of the public due to postulated accidents is much lower than at an operating power plant. Therefore, some adndnistrative controls have been simplified as appropriate. The specific provisions of the current TTS are discussed separately below. The Trojan organization is currently in transition from an interim organizational structure to a long term structure appropriate for the permanently defueled otatus of the facility. Current job titles are listed in the proposed PDTS followed by the long term organization title in < >. This has been done to avoid the need for a future license amendment request solely to address the planned title changes.

i TTS Section 6.1 and 6.2 define the individual with overall responsibility for operation of the Trojan facility and other general organizational requirements. The content of these sections has been retained in PDTS 51 and 5.2. The PDTS sections are patterned after the format and wording of the improved standard technical specifications. However, the provisions of the current TTS that were recently incorporated by amendment 191 to facility operating license NPF-1 to address the permanently defueled condition have been retained. The provision contained in the improved standard technical specifications relating to the annual designation of the person responsible for the operational command function has not been incorporated into the proposed PDTS. The relatively small size and simplified structure of the Trojan facility staffmake such a provision unnecessary. These unique provisions include the minimum shift crew composition and the requirements related to certified fuel handlers. The protisions of TTS 6.2.2.h stating that an operator holding a Senior Reactor Operator (SRO) license is qualified as a certified fuel handler has been deleted as the SRO licenses at the Trojan facility are no longer being maintained. The specific provisions related to the composition of the fire brigade has not been retained consistent with the scope of the improved standard technical specifications. Also in l

accordance with the improved standard technical specifications, a requirement for maintenance of a fire protection program has been included in PDTS 5.7.2.7.

I TTS Section 6.3 specifies the requirements for qualifications of the facility staff. Tids specification has been retained without modification as PDTS 5.3.

TTS Section 6.4 specifies the requirements for certified fuel handlers and the fire brigade. The requirements for training of certified fuel handlers have been retained without modification as proposed PDTS 5.4. The requirement for training of certified fuel handlers has been retained per the current TTS. This pruv.sion was incorporated by amendment number 191 to facility operating license'NPF-1 to address the permanently defueled status of the Trojan facility. Consistent with the improved standard technical specifications contained in NUREG-1431, the specific training requirements for sine fire brigade are not specified in PDTS 5.4. However, also consistent with i

l Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 1 Page 34 of 50 the improved standard technical specifications, a requirement for maintenance of a fire protection

)

program has been included in PDTS 5.7.2.7.

j TTS Section 6.5 specifies the review and audit functions performed by the Plant Review Board l

(PRB) and the Trojan Nuclear Operations Board (TNOB). The review ar.d audit functions of the i

PRB and the TNOB have been combined under the responsibility of a single review committee l

referred to in the proposed PDTS as the Independent Review and Audit Committee (IRAC).

With the termination of reactor operations at the Trojan facility and the conversion of the operating license to a possession only license, the scope and complexity of activities at the facility have been greatly reduced. Consequently, the permanent staff supporting the Trojan facility will j

also be much smaller than those required to support an operating power plant. The reduced scope of activities and limited staff make operation of two review committees unnecessaiy. The responsibilities of the IRAC encompass the majority of the functions previously performed by the PRB and the TNOB. Selected functions have been modified consistent with the scope of activities at a permanently defueled facihty.

TTS Section 6.6 covers requiremer.:s for events that are reportable per 10 CFR 50.73. Consistent with the content of the improved standard technical specifications, these provisions are not j

included in the proposed PDTS. The requirements for reporting of events are specified in the j

applicable regulations and additional detail is not necessary in the PDTS.

TTS Section 6.7 specifies the actions to be taken in the event of a violation of the safety limits j

contained in TTS Section 2.0. As noted in the discussion of TTS Section 2 above, the safety j

limits are no longer applicable and have not been retained in the proposed PDTS. Therefore, the provisions ofTTS Section 6.7 are unnecessary and have not been retained in the proposed PDTS.

j TTS Section 6.8 specifies requirements for procedures and programs. This specification has been j

retained, with appropriate modifications, as proposed PDTS 5.7. PDTS 5.7.1.1 covers the scope of required procedures. This section is consistent with the existing TTS and the improved standard technical specifications with the following exceptiont TTS 6.8.1.a covers procedures recommended in Appendix A of Regulatory Guide 1.33, November 1972. Tlus wording has been modified to clarify that only such procedures applicable to the safe storage ofirradiated fuel are included in this item (PDTS 5.7.1.1.a) and updated to reference Regulatory Guide 1.33, February 1978. TTS 6.8.1.b, refueling operations, has been deleted in the proposed PDTS since refueling operations will no' longer be conducted at the Trojan facility. TTS 6.8.1.c concerning procedures for surveillance and test activities of safety-related equipment has also been deleted consistent with the scope of procedures included in the improved standard technical specifications. This provision is redundant to TTS 6.8.1.a that is included in the PDTS as noted above. TTS Sections 6.8.2 and 6.8.3 cover permanent and temporary changes to procedures. The provisions of these sections have been retained as proposed PDTS 5.7.1.2 and 5.7.1.3. PDTS 5.7.1.2 includes a j

provision requiring that changes to procedures be subject to an independent review. This i

provision was included since the IRAC is not required to review each procedure change as discussed above. PDTS 5.7.1.3 covers temporary changes to procedures. The proposed PDTS reduces the number of members of the facility management staff required to approve temporary changes to procedures from two in the current TTS to one. This is consistent with the reduced 1

l F

Trojan Nuclear Plant Document Control Desk i

l Docket 50-344 July 31,1993

)

License NPF-1 Attachment II Page 35 of 50 I

i l

scope and complexity of procedures required to support the permanently defueled facility and j

l with the smaller management staff. TTS 6.8.3.c addressing PGE organizations other than the l

facility staff has been deleted since this distinction is no longer practicable with the reduced size of the organization.

TTS Section 6.8.4 addresses programs that are required to be maintained and implemented.

Program requirements are retained in the proposed PDTS 5.7.2. The existing programs addressed in TTS 6.8.4 are not applicable to a permanently defueled facility and have not been retained in

)

the proposed PDTS. These include TTS 6.8.4.a, primary coolant sources outside containment;

)

i l

TTS 6.8.4.b, in-plant radiation monitoring; TTS 6.8.4.c, secondary water chemistry; and TTS 6.8.4.d, post-accident monitoring. The in-plant radiation monitoring program required by TTS j

I 6.8.4.d provided for the monitoring of airborne iodine concentrations in vital areas under accident conditions. However, as demonstrated above, the limiting design basis accidents no longer have the potential for generating high radiation levels, and the need for short term access to specific plant areas to cope with various accident scenarios has been eliminated. Therefore, a specific l

in-plant radiation monitoring program is no longer necessary or appropriate.

l The applicable programs included in the standard technical specifications have been incorporated i

in the proposed PDTS. These include PDTS 5.7.2.1, radiation control program; PDTS 5.7.2.2, process control program; PDTS 5.7.2.3, off-site dose calculation manual; PDTS 5.7.2.4, radioactive effluent controls program; PDTS 5.7.2.5, radiological environmental monitoring program; PDTS 5.7.2.6, Storage Tank Radioactivity Monitoring Program; and PDTS 5.7.2.7, fire I

protection program. One additional program requirement for a spent fuel pool water chemistry program has been included in the proposed PDTS that is not currently contained in the TTS or in the improved standard technical specifications. This program is similar to the secondary water chemistry program included in the standard technical specifications and is intended to provide controls to minimize any potential long term effects of corrosion on components in the spent fuel pool.

TTS Section 6.9 contains requirements for submitting various reports. This section has been retained, with appropriate modifications, as proposed PDTS 5.8. Several reports listed in TTS Section 6.9 are no longer appropriate for a permanently defueled facility and have been deleted in the proposed PDTS 5.8. These include the results of steam generator tube inservice inspections required by 6.9.1.5.b, documentation of challenges to the pressurizer power operated relief valves or safety valves required by 6.9.1.5.c, results of specific activity analyses of the primary coolant required by 6.9.1.5.d, startup reports required by TTS 6.9.1.1-3, monthly operating reports required by TTS 6.9.1.6, and the core operating limits report required by TTS 6.9.1.7. TTS Section 6.9.2 covering special reports has also been deleted since the referenced LCOs or surveillance sections have not been retained in the proposed PDTS.

The requirements for submittal of a semiannual radioactive effluent release report contained in TFS Sections 6.9.1.5.3 and 6.9.1.5.4 have also been deleted in the proposed PDTS.10 CFR 20.106, " Radioactivity in efIluents to unrestricted areas," sets limits on the release of radioactive l

cfiluents applicable to licensees of the NRC. For power reactors,10 CFR 50.36a, " Technical Specifications on efIluents from nuclear power reactor," and 10 CFR 50 Appendix 1, " Numerical l

l

Trojan Nuclear Plant Document Control Dcsk Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 36 of 50 Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion 'As Low As Is Reasonably Achievable' for Radioactive Material in Light Water-Cooled Nuclear Power Reactor EfIluents," provide additional restrictions. The provisions of Appendix I are intended to ensure that the radioactive effluents produced as a result of nuclear power reactor operations are processed and treated using the installed radioactive waste treatment systems to reduce the level of such efiluents to the extent practicable. The principal source of such efIluents at nuclear power reactors are the continuous purification of the reactor coolant to remove radioactive materials resulting from the activation ofimpurities in the coolant or the leakage of fission products from the fuel rods during power operations. The provisions of Appendix I are not appropriate for facilities other than nuclear power reactors as noted in Section I of Appendix I to 10 CFR 50. Since the reactor at the Trojan facility has been permanently shutdown and defueled, radioactive waste associated with reactor operations is no longer being produced. The levels of radioactive efIluents associated with the continued storage ofirradiated fuel are expected t

to be only a small fraction of those previously produced. Therefore, the administrative requirements associated with demonstrating compliance with the limits of Appendix I to 10 CFR i

50 are no longer necessary or appropriate. Therefore, the requirement for a semiannual radioactive effluent report has not been retained in the proposed PDTS. As noted above, a new requirement has been included in the proposed PDTS (5.7.2.4) for the establishment of a

" Radioactive Efiluent Controls Program." As stated in the PDTS 5.7.2.4, the purpose of this program is to provide appropriate controls to maintain the doses to members of the public from radioactive effluents as low as reasonably achievable. This program requirement is consistent with the improved standard technical specifications except that provisions in the standard l

technical specifications explicitly related to compliance with Appendix I have been deleted. As noted above, the proposed PDTS 5.7.2.5 also continues to provide for a " Radiological I

Environmental Monitoring Program." This program provides for monitoring of radionuclides in the environs of the plants to verify the accuracy of effluent monitoring and modeling of environmental exposure pathways.

I The provision for inclusion of a Land Use Census in the radiological emironmental monitoring program as contained in the improved standard technical specifications has not been retained in the proposed PDTS. As noted in the bases for TTS 3.12.3, the purpose of this census is to satisfy the requirements of Section IV.B.3 of Appendix I to 10 CFR 50 by identifying the need for potential changes in the environmental monitoring program. As noted above, the magnitude of radioactive effluents at the Trojan facility is much less than those associated with operation of a power reactor and the provisions of Appendix I are no longer applicable to the Trojan facility.

Therefore, a periodic land use census is no longer needed and has not been included in the proposed PDTS.

TTS Section 6.10 contains requirements for the retention of various types of records. This specification has been modified as appropriate and retained as PDTS 5.9. Consistent with the improved standard technical specifications, the retention period for licensee event repons, radioactive shipments and changes to specified procedures has been changed from five years to three years. Several record types have not been retained in the proposed PDTS as they are no longer applicable as demonstrated by the discussions of specific TTS sections. These include TTS 6.10.2.f covering records of transient or operational cycles, TTS 6.10.2.h covering records of i

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II -

Page 37 of 50 inservice inspections, TTS 6.10.2.1 covering records of environmental qualification of electrical equipment and TTS 6.10.2.n covering records related to hydraulic and mechanical snubbers. TTS 6.10.2.k covering records ofreview committee meetings has also been deleted from this section to be consistent with the format of the improved standard technical specifications, however, PDTS 5.9.3.h covers the records of review and audits required to be conducted by the review committee. The records of review committee meetings are also covered by PDTS 5.5.2. In addition, the wording of several items has been modified to clarify that the scope of the required records is limited to those activities affecting the safe storage ofirradiated fuel. With the exceptions noted the content of the proposed PDTS is consistent with the improved standard technical specifications contained in NUREG-1431.

TTS Section 6.11 specifies the requirement for a radiation protection program. This specification has been retained without modification as PDTS 5.7.2.1 and is consistent with the improved standard technical specifications contained in NUREG-1431.

TTS Section 6.12 specifies requirements for the control of high radiation areas. The provisions of this TTS section are included in proposed PDTS 5.10. Additional provisions contained in the improved standard technical specifications have also been included in this PDTS section. The scope and content of PDTS 5.10 are consistent with the improved standard technical specifications contained in NUREG-1431.

TTS Section 6.13 specifies requirements related to the environmental qualification of safety-related electrical equipment. The environmental qualification requirements for safety-related electrical equipment require that equipment be shown capable of functioning in the harsh environments resulting from a loss of coolant accident or a rupture of a high-energy line.

Since the reactor at the Trojan facility has been permanently shutdown and defueled, the postulated accidents that could produce harsh environments are no longer possible. It should also be noted that this TTS provision duplicates the requirements of 10 CFR 50.49 and similar provisions are not contained in the improved standard technical specifications ofNUREG-1431.

TTS Section 6.14 specifies requirements for a Process Control Program (PCP) covering the solidification of wet radioactive waste. These requirements have been incorporated into proposed PDTS 5.7.2.2. The wording of PDTS 5.7.2.2 is consistent with the improved standard technical specifications contained in NUREG-1431.

5 *cetion 6.15 specifies requirements for an Off-site Dose Calculation Manual (ODCM) covering the methodology used in the calculation of off-site doses resulting from radioactive effluents. These requirements have been incorporated into proposed PDTS 5.7.2.3. The wording of PDTS 5.7.2.3 is consistent with the improved standard technical specifications contained in NUREG-1431.

t TTS Section 6.16 addresses major changes to radioactive waste treatment systems. A pending license amendment request dated June 9,1993, has proposed deletion of these sections consistent with NRC guidance. Therefore, these sections have not been retained in the proposed PDTS.

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 38 of 50 This is consistent with the scope of the improved standard technical specifications contained in NUREG-1431.

Standard 1 - Operation of thefacility in accordance with theproposed amendment would not involve a significant increase in theprobability or consequences ofan accidentpreviously evaluated.

This section of the TTS provides for administrative controls over facility activities and does not directly affect the design of stmetures or equipment necessary for the safe storage ofirradiated fuel or the methods used for handling and storage of such fuel in the spent fuel pool. The proposed changes to this section delete provisions that are no longer applicable due to the permanently defueled status of the facility and modifies other controls as appropriate for the reduced scope of activities at a permanently defueled facility. The revised administrative controls continue to provide for reviews and audits of activities affecting the safe storage ofirradiated fuel including the modifications of applicable stmetures, equipment and procedures. Therefore, operation of the facility in accordance with the proposed changes to this TFS section does not involve any increase in the probability or consequences of any accident previously evaluated.

Standard 2 - Operation of thefacility in accordance with theproposed amendment would not create thepossibility of a new or different kind ofaccidentfrom any accidentpreviously evaluatest The revised administrative controls do not alter the design of structures or equipment needed for the safe storage ofirradiated fuel or the methods of fuel handling and storage in the spent fuel pool. The proposed continue to provide for reviews and audits of activities affecting such activities. Therefore, operation of the facility in accordance with the proposed changes to this TTS section would not create the possibility of a new or different kind of accident from any accident previously evaluated.

Standard 3 - Operation of thefacility in accordance with theproposed amendment would not involve a sigmjicant reduction in a margin ofsafety.

The proposed changes have no impact on the analyses of postulated design basis accidents remaining applicab!: to the Trojan facility. Therefore, operation of the facility in accordance with the proposed changes to this TTS section would not involve a reduction in any margin ofsafety.

u

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II l

Page 39 of 50 AdditionalSpecifications Included in the PDTS Additional Specification Included in the PDTS - Two LCOs that are not currently contained in the TTS were identified as appropriate for the proposed PDTS. These specifications were determined to be necessary since they involve parameters that are initial conditions for postulated DBAs. These specifications are discussed separately below.

PDTS 3.1.2 places a limit on the minimum soluble boron concentration in the spent fuel pool.

The design of the spent fuel pool is based on the use of unborated water, which maintains a subcritical condition (kg 0.95) during normal operation with the spent fuel racks fully loaded.

However, the water in the spent fuel pool normally contains soluble boron. This results in large subcriticality margins under actual normal conditions. The presence of this soluble boron is credited in the analyses of abnormal conditions. Credit for soluble boron under abnormal or accident conditions is allowable since only a single accident need be considered at one time. Most accident conditions do not result in an increase in the reactivity of the spent fuel pool. However, the analyses performed to evaluate the effects of a postulated drop of an irradiated fuel assembly on the spent fuel racks assumed the presence of 2000 ppm soluble boron in the spent fuel pool water. The presence of soluble boron was also assumed in the evaluation of a spent fuel pool heatup. The negative reactivity effect of the soluble boron compensates for any increased reactivity caused by postulated accident scenarios. The accident analyses are provided in the SAR and in PGE-1037, " Spent Fuel Storage Rack Replacement Report," dated July 1983. PDTS 3.1.2 limits the boron concentration to no less than 2000 ppm to preserve the initial conditions assumed in the accident analyses.

PDTS 3.1.3 limits the maximum spent fuel pool coolant temperature. As described in the discussion of the revised accident analyses for permanently defueled conditions, a forced cooling system is not necessary to provide an adequate heat sink for the irradiated fuel assemblies stored in the spent fuel pool. An adequate heat sink is provided as long as the fuel assemblies remain covered with water. However, should the spent fuel pool be allowed to heatup, the inventory of cooiant in the pool will eventually begin to be reduced due to boiling and evaporation. Analyses I

show that over ten days are available before the water in the pool is reduced to a level ten feet above the top of the fuel assemblies. This is more than sufficient time to allow repairs of the forced cooling system or to establish a source of makeup flow to the pool (less ihm eight gallons per minute are required to offset evaporative losses). An initial pool temperature of 140* F is assumed in the analyses of a prolonged loss of forced cooling. Therefore, this parameter meets Criterion Two of the screening criteria and a limitation on this parameter is included in the i

proposed PDTS. This limitation ensures that actions are taken to maintain the initial conditions assumed in the analyses. The new LCO requires ti.at immesate action be taken to initiate restoration of the pooi temperature to within limits and to verify that a source of makeup water is available. Although over ten days are available to establish makeup flow, this early action is considered prudent to ensure that makeup water is available if required.

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 40 of 50 Standard 1 - Operation of thefacility in accordance with theproposed amendment would not involve a significant increase in theprobability or consequences of an accidentpreviously evaluated.

The proposed additional restrictions on the boron concentration and temperature in the spent fuel pool have no impact on the probability or consequences of the remaining applicable design basis accidents. These restrictions reflect normal operating conditions and preserve initial conditions assumed in the analyses of postulated DBAs and ensure that the consequences of such DBAs are l

consistent with the analyses. Therefore, operation of the facility in accordance with the proposed changes to this TTS section does not involve any increase in the probability or consequences of any accident previously evaluated.

Standard 2 - Operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed additional restrictions on the boron concentration and temperature in the spent fuel pool reflect normal operating conditions and preserve initial conditions assumed in the analyses of postulated DBAs. These additional restrictions do not involve changes to any structure or equipment affecting the safe storage ofirradiated fuel or the methods of handling or storing such fuel. Therefore, operation of the facility in accordance with the proposed changes to this TTS section would not create the possibility of a ne.v or ditrerent kind of accident from any accident i

previously evaluated.

.1 Standard 3 - Operation of thefacility in accordance with theproposed amendment u ould not i

involve a sigmjicant reduction in a margin ofsafety.

The proposed additional restrictions on the boron concentration and temperature in the spent fuel R

pool initial conditions assumed in the analyses of postulated DBAs and ensure that margins of -

safety contained in the analyses are maintained Therefore, operation of the facility in accordance with the proposed changes to this TTS section would not involve a reduction in any margin of safety.

i i

l 1

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 41 of 50 EnvironmentalImpact Consideration Determination This amendment request meets the criteria speci6ed in 10 CFR 51.22 (c)(9) for categorical exclusion or othenvise not requiring environmental review. Specific criteria contained in this section are discussed below:

1. The amendment involves no significant hazards consideration. As demonstrated above, i

this requested amendment does not involve any significant hazards considerations.

2. There is no significant change in the types or significant increase in the amounts of any l

effluents that may be released offsite. The requested license amendment proposes to modify the Trojan Possession Only License to reflect the permanently defueled and shutdown condition of the plant. Administrative controls on olant effluents remain in place to ensure applicable regulatory guidelines on plant effluents that may be released offsite are met. Thus, no anticipated plant activities as a result ofissuance of this requested amendment should result in a significant change in the types of or significant increase in the amounts of any effluents that may be released offsite.

3. There is no significant increase in individual or cumulative occupational radiation worker exposure. The proposed amendment will provide relief from certain operational requirements that are inappropriate for a permanently shutdown and defueled plant. These operational requirements (surveillance testing, inspections, etc.), in some cases, result in the accrual of occupational radiation exposure for Trojan workers. As the requirements for conducting these activities are reduced, many of these activities may be eliminated.

The elimination of these unnecessary activities is expected to result in a decrease in the cumulative radiation exposure. In addition, administrative controls shall remain in place to ensure that individual occupational radiation exposure is maintained below applicable regulatory requirements.

On the basis of the preceding discussion, it has been concluded that the proposed amendment is acceptable and meets the eligibility criteria for categorical exclusion set forth in f

10 CFR 51.22 (c)(9), and thus no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

Summary Table The following table presents a comparison of current Trojan technical specifications to the -

NUREG-1431 improved standard technical specifications and the proposed Trojan PDTS.

1 1

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 42 of 50 Comparison of Current Trojan Technical Specifications to Proposed Permanently Defueled Technical Specifications l

Current TTS Improved STS Trojan PDTS l.1 - Defined Terms 1.1 - Definitions 1.1 - Definitions 1.2 - Thermal Power 1.1 - Defmitions N/A 1.3 -- Rated Thermal Power 1.1 - Dermitions N/A 1.4 - Operational Mode or 1.1 - Definitions N/A Modes 1.5 - Action 1.1 -- Definitions 1.1 - Definitions f

1.6 - Operable - Operability 1.1 -- Definitions N/A 1.7 - Reportable Event Not Included N/A l.8 -- Containment Integrity Not Included N/A 1.9 - Channel Calibration 1.1 - Definitions N/A l

1.10 - Channel Check 1.1 - Definitions N/A 1.11 - Channel Functional 1.1 -- Definitions N/A Test 1.12 - Core Alteration 1.1 - Definitions N/A 1.13 - Shutdown Margin 1.1 - Definitions N/A 1.14 -- Identified Leakage 1.1 - Definitions N/A 1.15 - Unidentified Leakage 1.1 -- Definitions N/A 1.16 - Pressure Boundary 1.1 - Definitions N/A Leakage 1.17 - Controlled Leakage Not Included N/A 1.18 - Quadrant Power Tilt 1.1 -- Definitions N/A Ratio 1.19 - Dose Equivalent I-131 1.1 - Definitions N/A 1.20 - Staggered est Basis 1.1 - Definitions N/A 1.21 - Frequency Notation 1.4 -- Frequency 1.4 - Frequency 1.22 - Reactor Trip System 1.1 - Definitions N/A Response Time 1.23. - Engineered Safety 1.1 - Definitions Feature Response N/A Time 1.24 - Axial Flux Difference 1.1 - Definitions N/A l

Trojan Nuclear Plant Document Control Desk i

Docket 50-344 July 31,1993 License NPF-1 Attaciunent II Page 43 of 50 t

Comparison of Current Trojan Technical Specifications to Proposed Permanently Defueled Technical Specifications Current TFS Improved STS Trojan PDTS 1.25 - Physics Tests 1.1 - Definitions N/A 1.26 - Average 1.1 - Definitions N/A Disintegration Energy 1.27 - Source Check Not Included N/A-1.28 - Process Control Program Included in Program Included in

[

Program Section 5.7.2 Section 5.7.2 1.29 -- Solidification Not Included N/A 1.30 - Offsite Dose Program Included in Program Included in Calculation Manual Section 5.7.2 Section 5.7.2 l.31 - Gaseous Radwaste Not Included N/A Treatment System I

1.32 - Ventilation Exhaust Not Included N/A Treatment System 1.33 -- Purging Not Included N/A 1.34 - Liquid Radwaste Not Included N/A i

Treatment System 1.35 - Core Operating Limits 1.1 - Definitions N/A Report 1.36 - Member (s) of the Not Included N/A Public 2.1.1 - Reactor Core 2.1.1 - Reactor Core N/A 2.1.2 - Reactor Coolant 2.1.2 -- Reactor Coolant N/A System Pressure System Pressure 2.2.1 - Reactor Trip System 3.3.1 - Reactor Trip Instrumentation System N/A Setpoints Instrumentation Setpoints 3/4.0- Applicability 3.0 - Limiting Condition for 3.0 - Limiting Condition for Operation Operation Applicability Applicability and and Surveillance Surveillance Requirement Requirement Applicability Applicability i

Trojan Nuclear Plant Document Control Desk i

Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 44 of 50 i

Comparison of Current Trojan Technical Specifications to

)

Proposed Permanently Defueled Technical Specifications Current TTS Improved STS Trojan PDTS 3.0.1 - LCO Applicability 3.0.1 - LCO Applicability 3.0.1 - LCO Applicability 3.0.2 - Implementation of 3.0.2 - Implementation of 3.0.2 -- Implementation of LCO Actions LCO Actions LCO Actions 3.0.3 - Exceeding LCO 3.0.3 - Exceeding LCO N/A Actions Actions j

3.0.4 - Changes in Modes or 3.0.4 - Changes in Modes N/A Conditions or Conditions 3.0.5 - Power Sources 3.0.6 - Support Systems N/A i

4.0.1 - Applicability of SR 3.0.1 - Applicability of SR 3.0.1 - Applicability of j

Surveillance Surveillance Surveillance Requirements Requirements Requirements I

4.0.2 - 25% Extension of SR 3.0.2 - 25% Extension SR 3.0.2 -- 25% Extension of 1

Surveillance ofSurveillance Surveillance Frequencies Frequencies Frequencies j

4.0.3 - Failure to Perform SR 3.0.3 - Failure to SR 3.0.3 - Failure to i

Surveillance Perform Perform Requirements Surveillance Surveillance Requirements Requirements 4.0.4 - Entry into SR 3.0.4 - Entry into Operational Modes or Operational N/A Conditions Modes or Conditions 4.0.5 - ASME Code Class Program Included in i

1,2, and 3 -

Section 5.7.2 N/A Components 3/4.1 - Reactivity Control 3.1 - Reactivity Control N/A Systems Systems 3/4.2 - Power Distribution 3.2 - Power Distribution N/A Limits Limits 3/4.3 - Instrumentation 3.3 - Instrumentation N/A 3/4.3.1 - Reactor Trip 3.3.1 -- Reactor Trip System System N/A Instrumentation Instrumentation

~

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II l

Page 45 of 50 Comparison of Current Trojan Technical Specifications to Proposed Permanently Defueled Technical Specifications Current TTS Improved STS Trojan PDTS 3/4.3.2 - Engineered Safety 3.3.2 - Engineered Safety Feature Actuation Feature Actuation N/A

[

System System Instmmentation Instrumentation 3/4.3.3 - Monitoring Instrumentation 3/4.3.3.1 - Radiation Not Included N/A 3/4.3.3.2 - Movable Incore Not Included N/A Detectors 3/4.3.3.3 - Seismic Not Included N/A 3/4.3.3.4 - Meteorological Not Included N/A 3/4.3.3.5 - Remote 3.3.4 - Remote Shutdown N/A Shutdown System 3/4.3.3.6 - Chlorine 3.3.7 -- Control Room N/A i

Emergency Filtration System Actuation i

Instmmentation 3/4.3.3.7 - Fire Protection Not Included Deletion pending per previously proposed license l

amendment.

3/4.3.3.8 - Decouple Not Included N/A Switches l

3/4.3.3.9-Accident 3.3.3 - Post Accident Monitoring Monitoring N/A i

Instrumentation Instmmentation 3/4.3.3.10 - Radioactive Not Included Deletion pending per Liquid EfIluent previously proposed hcense Instmmentation amendment.

3/4.3.3.11 - Radioactive Not Included Deletion pending per Gaseous previously proposed license Efiluent amendment.

j Instrumentation i

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 46 of 50 Comparison of Current Trojan Technical Specifications to Proposed Permanently Defueled Technical Specifications Current TrS Improved STS Trojan PDTS i

3/4.3.3.12 - SO Detection 3.3.7 - Control Room 2

System Emergency Filtration System N/A Actuation Instrumentation-3/4.4 - Reactor Coolant 3.4 - Reactor Coolant N/A System System 3/4.5 - Emergency Core 3.5 - Emergency Core N/A Cooling System Cooling System 3/4.6 - Containment Systems 3.6 -- Containment Systems N/A 3/4.7 - Plant Systems 3.7 - Plant Systems 3.1 -- Defueled Systems (Selected LCOs) 3/4.7.1 - Turbine Cycle 3.7 - Various Sections N/A 3/4.7.2 - Steam Generator Pressure and Not Included N/A Temperature Limitation 3/4.7.3 - Component 3.7.7 -- Component Cooling N/A l

Cooling Water Water System System 3/4.7.4 -- Service Water 3.7.8 -- Senice Water N/A System System 3/4.7.5 - Ultimate Heat Sink 3.7.9 - Ultimate Heat Sink N/A 3/4.7.6 - Control Room 3.7.10 - Control Room Emergency Emergency Ventilation System Filtration System N/A 3.7.11 - Control Room Emergency Air Temperature Control System 3/4.7.7 - Sealed Source Not Included N/A Contamination

~_

i Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 47 of 50 i

Comparison of Current Trojan Technical Specifications to Proposed Permanently Defueled Technical Specifications Current TFS Improved STS Trojan PDTS 3/4.7.8 - Fire Suppression Not Included N/A Systems i

3/4.7.9 - Penetration Fire Not Included N/A Barriers

{

3/4.7.10 - Snubbers Not Included N/A l

3/4.7.11 -- Control Building Modification Not Included N/A Connection Bolts 3/4.8 - Electrical Power 3.8 -- Electrical Power N/A Systems Systems 3/4.9 -- Refueling Operations 3.9 - Refueling Operations 3.1 - Defueled Systems (Selected LCOs) 3/4.9.1 - Boron 3.9.1 -- Boron Concentration Concentration (Reactor Coolant N/A System and Refueling Canal)

-[,

3/4.9.2 - Instrumentation 3.9.3 - Neutron (Source Range Instrumentation N/A Neutron Flux) j 3/4.9.3 - Decay Time Not Included N/A 3/4.9.4 - Containment 3.9.4 -- Containment Building Penetrations N/A Penetrations 3/4.9.5 - Communications Not Included N/A i

3/4.9.6 - Manipulator Crane Not Included N/A Operability i

F 3/4.9.7 - Crane Travel - Fuel Not Included 3.1.4 - Spent Fuel Pool Load j

Building Restrictions t

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 48 of 50 Comparison of Current Trojan Technical Specifications to Proposed Permanently Defueled Technical Specifications Current TFS Improved STS Trojan PDTS 3/4.9.8 - Coolant Circulation 3.9.5 - RHR & Coolant Circulation - High Water Level N/A 3.9.6 - RHR & Coolant -

Circulation - Low Water Level 3/4.9.9 - Containment 3.3.6 - Containment Purge Ventilation and Exhaust N/A Isolation System Isolation Instrumentation 3/4.9.10 - Water Level -

3.9.7 -- Refueling Cavity N/A Reactor Vessel Water Level 3/4.9.11 - Storage Pool 3.7.15 - Fuel Storage Pool 3.1.1 - Spent Fuel Pool Water Water Level Water Level Level 3/4.9.12 - Spent Fuel Pool 3.7.13 - Fuel Building Air N/A Exhaust System Cleanup System 3/4.9.13 - Containment Not Included Purge Exhaust N/A System Operation 3/4.10 - Special Test Not Included N/A Exceptions 3/4.11 - Radioactive Not Included -

Deletion Pending per EfIluents (Program Required by Previously Proposed License Section 5.7.2)

Amendment 3/4.12 - Radiological Not Included Deletion Pending per Environmental (Program Required by Previously Proposed License Monitoring Section 5.7.2)

Amendment 5.1 - Site 4.1 - Site 4.1 - Site 5.2 - Containment Not Included N/A 5.3 - Reactor Core 4.2 - Reactor Core N/A.

5.4 - Reactor Coolant Not Included N/A System 1

t Trojan Nuclear Plant Document Control Desk Docket 50 344 July 31,1993 License NPF-1 Attachment II i

Page 49 of 50 Comparison of Current Trojan Technical Specifications to Proposed Permanently Defueled Technical Specifications Current TTS Improved STS Trojan PDTS 5.5 - Emergency Core Not Included N/A Cooling System 5.6 - Fuel Storage 4.3 - Fuel Storage 4.2 - Fuel Storage 5.7 - Seismic Classification Not Included N/A 5.8 - Meteorological Tower Not Included N/A Location 5.9 - Component Cyclic or Not Included N/A Transient Limit 6.1 - Responsibility 5.1 -- Responsibility 5.1 -- Responsibility 6.2 - Organizational 5.2 - Organization 5.2 - Organization Requirements 6.3 -- Facility Staff 5.3 -- Unit Staff 5.3 - Facility Staff Quanfications Qualifications Qualifications 6.4 - Training 5.4 - Training 5.4 - Training 6.5 - Review and Audit 5.5 -- Review and Audits 5.5 -- Review and Audits 6.6 - Reportable Event Not Included N/A Action l

6.7 - Safety Limit Violations 2.2 - SL Violations N/A 6.8 - Procedures and 5.7 - Procedures, 5.7 - Procedures, Programs Programs Programs and and Manuals Manuals 6.9 - Reporting 5.9 - Reporting 5.8 - Reporting l

Requirements Requirements Requirements j

6.10 - Record Retention 5.10 -- Record Retention 5.9 - Record Retention 6.11 - Radiation Protection 5.7.2.1 - Radiation 5.7.2.1 - Radiation Program Protection Protection Program Program 6.12 - High Radiation Area 5.11 - High Radiation Area 5.10 -- High Radiation Area 6.13 - Environmental Not Included N/A Qualification 6.14 -- Process Control 5.7.2.2-- Process Control 5.7.2.2 - Process Control Program Program Program i

Trojan Nuclear Plant Document Control Desk Docket 50-344 July 31,1993 License NPF-1 Attachment II Page 50 of 50 Comparison of Current Trojan Technical Specifications to Proposed Permanently Defueled Technical Specifications Current TFS Improved STS Trojan PDTS 6.15 - Off-site Dose 5.7.2.3-Off-site Dose 5.7.2.3 -- Off-site Dose Calculation Manual Calculation Calculation Manual Manual 6.16 - Major Changes to Radioactive Waste Not Included N/A Treatment Systems l

-l