ML20057D079
| ML20057D079 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 09/22/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20057D070 | List: |
| References | |
| NUDOCS 9310010079 | |
| Download: ML20057D079 (6) | |
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WASHINGTON, D.C. 20555 0001 SAFETY EVALUATION BY THE OFF'CE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 192 TO FACILITY OPERATING LICENSE NO. NPF-1 PORTLAND GENERAL ELECTRIC COMPANY THE CITY OF EUGENE. OREGON TROJAN NUCLEAR PLANT DOCKET NO. 50-344
1.0 INTRODUCTION
By letter dated March 16, 1993, Portland General Electric Company (PGE or the licensee) submitted a request for changes to the Facility Operating License No. NPF-1 for the Trojan Nuclear Power Plant (Trojan or TNP). The proposed changes would relocate those portions of the TNP Technical Specifications (TS) related to the TNP fire protection program (FPP) from the Trojan TS to Topical Report PGE-1012 " Trojan Nuclear Plant Fire Protection Plan," in accordance with the guidance provided in NRC Generic Letter (GL) 86-10, " Implementation of Fire Protection Requirements," April 24, 1986, and Generic Letter 88-12,
" Removal of Fire Protection Requirements from Technical Specifications,"
August 2, 1988.
The amendment also revises the license condition 2.C.(8) in Operating License NPF-1.
The staff's evaluation of the requested changes is based on review of the licensee letter of March 16, 1993, the supporting materials provided with the letter, and discussions held at the Trojan site on July 20, 1993, which clarified the license condition and did not alter the previous determination of no significant hazards consideration.
2.0 BACKGROUND
Trojan is presently in a shutdown, non-operating, and defueled condition.
In a letter of February 2, 1993, the licensee notified the NRC that all reactor fuel had been parmanently removed from the Trojan reactor vessel and placed in the spent fuei pool.
In a letter of February 17, 1993, the licensee notified the NRC that PGE will not move fuel back into the Trojan containment building without prior NRC approval. On March 25, 1993, the NRC staff issued an order confirming the licensee commitment not to move fuel back into the containment building without prior NRC approval. This order serves to require the plant to remain in the non-operating and defueled condition.
The NRC, by letter of by 5,1993, amended Facility Operating License No. NFP-1 for Trojan to a possession only license (POL).
i 9310010079 930922 PDR ADOCK 05000344 i
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. 2.1 DISCUSSION AND EVALUATION The licensee proposed to relocate the following Trojan TS sections to Topical Report PGE-1012.
3/4.3.3.7 Fire Protection Instrumentation Table 3.3-10 Fire Detection Instruments 3/4.7.8.1 Fire Suppression Water System 3/4.7.8.2 Spray, Sprinkler, and/or Deluge Systems 3/4.7.8.3 Fire Hose Stations Table 3.7.4 Fire Hose Stations 3/4.7.9 Penetration Fi e Barriers B3/4/.3.3.7 Fire Detection Instrumentation Bases B3/4.7.8 Fire Suppression Systems Bases B3/4.7.9 Penetration Fire Barriers Bases 6.2.2.f Facility Staff (Fire Brigade) 6.4.2 Training (Fire Brigade)
The licensee also proposed to add an administrative control to TS Section 6.5.1.6m requiring Plant Review Board review of changes to the Trojan FPP.
In addition, the licensee proposed to delete the special reporting requirements in TS Section 6.9.2 that are applicable to fire protection. The reporting requirements of Title 10, Code of Federal Reaulations, Part 50, Sections 72 and 73 (10 CFR 50.72 and 50.73) will govern as specified by Section E of Generic Letter 86-10.
The licensee also proposed to revise License Condition 2.C.(8) to conform to the standard license condition specified in Generic Letter 86-10 with consideration that Trojan is permanently shut down.
The staff reviewed the license amendment request for Trojan against the guidance provided in Generic Letters 86-10 and 88-12. Generic Letter 86-10 requested that licensees incorporate the NRC-approved fire protection program in their Final Safety Analysis Reports. GL 88-12 addressed the elements a licensee should include in a license amendment request to remove fire protection requirements from TS.
These elements were:
(1) the NRC-approved fire protection program must be incorporated into the FSAR; (2) the limiting conditions for operations and surveillance requirements associated with fire detection systems, fire suppression systems, fire barriers, and the administrative controls that address fire brigade staffing would be relocated l
from the TS (the existing administrative controls related to fire protection i
audits would be retained in the TS); (3) all operational conditions, remedial actions, and test requirements presently included in the TS for these systems, as well as the fire brigade staffing requirements, shall be incorporated into the fire protection program; (4) the standard fire protection license condition in GL 86-10 must be included in the license; (5) the administrative controls section of the TS shall be augmented to support the fire protection program by giving the Unit Review Group (Onsite Review Group) responsibility for the review of the fire protection program and implementing procedures and the submittal of recommended changes to the Company Nuclear Review and Audit Group (Offsite or Corporate Review Group); (6) fire protection program implementation shall be added to the list of elements for which written procedures shall be established, implemented, and maintained.
l
. PGE incorporated its fire protection program into PGE-1012, " Trojan Nuclear Plant Fire Protection Plan," Section 9.5.1 of the Trojan FSAR, by reference in July 1988. The operability and surveillance requirements for the detection systems, fire suppression systems, fire barriers, and fire brigade t'affing requirements as defined in the current TS were incorporated into PGE-1012, and by reference in Trojan FSAR Section 9.5.1.
TS relating to the fire protection audits (lS 6.5.2.le and TS 6.5.1.6.m) have been added and require that the Plant Review board review the fire protection program and implementing procedures and that the plant review board shall function to review the fire protection program and implementing procedures. Therefore, the licensee has satisfied Elements 1 through 3 of GL 88-12.
The standard fire protection license condition, which was described in GL 86-10, is not applicable to TNP because Trojan is permanently shut down.
Consequently, in its submittal the licensee modified the license condition requirement.
Based on discussions between the NRC staff and the licensee on July 20, 1993, held at the Trojan site, the staff and the licensee further modified the license condition to read as follows:
The licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in PGE-1012, " Trojan Nuclear Plant Fire Protection Plan" and as approved in the SER dated September 22, 1993 subject to the following provision:
The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely impact the safe storage of irradiated fuel or increase the likelihood of an offsite release of radioactive material due to a fire.
The intent of the GL 86-10 license condition is to ensure that the licensee does not alter specific features of the approved program which would adversely affect the ability to achieve and maintain safe shutdown and, therefore, the ability to reduce the potential offsite radiological consequences of fire.
Because Trojan is in a permanently shutdown and defueled condition and the March 25, 1993, order precludes movement of fuel into the containment without l
prior NRC approval, it is not necessary for the Trojan license condition to address achieving and maintaining safe shutdown. Therefore, the staff has determined that the modified license condition proposed by the licensee adequately addresses offsite release of radioactive material for the conditions at Trojan, meets the intent of GL 86-10, and satisfies Element 4 of GL 88-12.
Elements 5 and 6 in GL 88-12 addressed changes to the administrative controls section of the TS. As requested by GL 88-12, PGE added TS to Section 6.0.
Specifically, 6.5.1.m will be added to include the review of the fire protection program and implementing procedures as an additional responsibility of the plant review board.
Element 6 concerned adding the fire protection program implementation to the list of elements for which written procedures shall be established, implemented, and maintained.
TS 6.8.1 already addresses the fire protection program, therefore, no changes are required. The licensee has satisfied Elements 5 and 6 of GL 88-12.
. Based on the above. evaluation and with the modifications noted, the staff has concluded that PGE has followed the guidance provided by the NRC in GL 86-10 and GL 88-12 and, therefore, the requested changes to the Fire Protection Program are acceptable.
3.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION
DETERMINATION The Commission regulations in 10 CFR 50.92 state that the Commission may make a final determination that a license amendment involves no significant hazards considerations if operation of the facility in accordance with the amendment would not:
(1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.
The Commission has determined that the amendment involves no significant hazards consideration per 10 CFR 50.92, based on the licensee's analysis provided in their March 16, 1993, letter and presented below:
1.
The proposed license amendment does not involve a significant increase in the probability or the consequences of an accident previously evaluated.
This amendment merely relocates the fire protection program elements from the [ Trojan Technical Specifications) TTS to PGE-1012. No change is being made to the content of the TTS being relocated. Operating limitations will continue to be imposed, and required surveillance will continue to be performed in accordance with written procedures and instructions auditable by the NRC.
Although proposed future changes to the fire protection program elements previously located in the TTS will no longer be controlled by 10'CFR 50.90, proposed changes to the TS requirements relocated to PGE-1012 will be evaluated by a safety evaluation in accordance with the requirements of 10 CFR 50.59 to determine whether an unreviewed safety question exists.
Changes that do represent an unreviewed safety question will receive prior NRC approval before implementation.
Thus, programmatic controls will continue to assure that this change will not have the effect of permitting future proposed fire protection program changcs to create an unreviewed safety question.
It is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.
The proposed license amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
j PGE-1012, incorporated by reference in Trojan FSAR Section 9.5.1, contains the Trojan fire hazards analysis.
This amendment merely relocates the fire protection TS requirements from the TTS to PGE-1012.
No change to 1
the fire protection TS rrouirements is being made and thus the change does not create the possibility
- a new or different kind of accident from any accident previously evalue a
. t As noted above, proposed changes to the TS requirements relocated to PGE-1012 will be evaluated by a safety evaluation in accordance with the requirements of 10 CFR 50.59 to determine whether an unreviewed safety question exists. Changes that do represent an unreviewed safety question will receive prior NRC approval before implementation.
3.
The proposed license amendment does not involve a significant reduction in the margin of safety.
This change does not involve a reduction to the approved fire protection program or TS fire protection requirements. The TS fire protection requirements are being relocated, without alteration to PGE-1012. Since there is no change to the requirements, there is no reduction in the-margin of safety.
As noted above, proposed changes to the TS requirements relocated to PGE-1012 will be evaluated by a safety evaluation in accordance with the requirements of 10 CFR 50.59 to determine whether an unreviewed safety question exists. Changes that do represent an unreviewed safety question will receive prior NRC approval before implementation.
The NRC staff has reviewed the licensee analysis.
Based on this review, which also took into consideration the revised license condition, the staff concludes that the analysis demonstrates that the applicable criteria are met.
i Accordingly, the Commission has made a final determination that the amendment involves no significant hazards consideration.
4.0 STATE CONSULTATION
In accordance with the regulations of the Commission, the Oregon State official was notified of the proposed issuance of the amendment.
The State official had one comment involving licensee plans to implement changes to the fire protection plan under 10 CFR 50.59 subsequent to approval of this amendment. Discussions between the licensee, the State official, and the NRC staff resolved the issue to the satisfaction of the State official.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant chan,e in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (58 FR 34088 and 58 FR 46665). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
6.0 EXIGENT NOTICE Public notice of consideration of issuance of this amendment request was published on June 23, 1993, in the FEDERAL REGISTER (58 FR 34088) as required by Commission regulation 10 CFR 50.9)(a)(2). However, the NRC staff noted that because of an administrative error, the notice did not identify that in addition to relocating the Fire Protection Program, the proposed amendment i
included the revised license condition. Consequently, consideration of issuance of the amendment request was republished in a 15-day public (exigent) notice on September 2, 1993, in the FEDERAL REGISTER (58 FR 46665).
Portland General Electric submitted a timely application for this proposed amendment.
The exigent notice was issued specifically to identify the inclusion of the revised license condition in the amendment request.
It was issued as an exigent notice because more than 60-days had already been provided for public comment and an additional 30 days for public comment would delay issuance of the amendment until the next quarter. This delay could cause the licensee to perform fire protection-related surveillances which are no longer necessary in the shutdown and defueled condition in areas within the containment which would result in unnecessary radiological exposure to personnel. Therefore, exigent circumstances exist which warrant that this action be processed in less than 30 days.
7.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the regulations of the Commission, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors:
A. Singh M. Webb Date: September 22, 1993
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