ML20135C352

From kanterella
Jump to navigation Jump to search
Annual Rept of Trojan Nuclear Plant for 1996
ML20135C352
Person / Time
Site: Trojan File:Portland General Electric icon.png
Issue date: 12/31/1996
From: Quennoz S
PORTLAND GENERAL ELECTRIC CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
PGE-1015-96, VPN-012-97, VPN-12-97, NUDOCS 9703030514
Download: ML20135C352 (51)


Text

i i

m e i Plothrid h BectricCcivipesif l l

Stephen M. Quennoz l Trojan Site Executive l i

l l

1 February 24,1997 l VPN-012-97 Trojan Nuclear Plant I Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Dear Sirs:

PGE-1015-96. " Annual Reoort of the Trojan Nuclear Plant"  ;

The enclosure to this letter provides one copy of Portland General Electric Company's " Annual Report of the Trojan Nuclear Plant" for the calendar year 1996.

Sincerely, W ;MYfre Stephen M. Quennoz Trojan Site Executive Enclosure c: D. Stewart-Smith, ODOE R. A. Scarano, NRC Region IV M. T. Masnik, NRC, NRR 9703030514 961231 PDR ADOCK 05000344 R PDR lill.EEE!EP5P.IIJill l

l l

l 030089 71760 Columbia River Highway, Rainier, OR 97048

503/556 3713 l \

lI lI

!I lI Trojan Nuclear Plant lI ANNUAL REPORT OF TROJAN NUCLEAR PLANT FOR 1996 i l g PORTLAND GENERAL ELECTRIC COMPANY I

I I

I I

PGE-1015-96 I

I I

I I

J

II PGE-1015-96 jI i

\

1 I \

i l

)

!I 4 l 1

1996 ANNUAL REPORT i i il i

er

g lE TROJAN NUCLEAR PLANT

!I 1

lI i

lI i

i l

il  !

I  ;

Docket 50-344 License NPF-1 I

I I PORTLAND GENERAL ELECTRIC COMPANY 121 S. W. Salmon Street I Portland, Oregon 97204 I

I TABLE OF CONTENTS

.I I =

INTRODUCTION &

SUMMARY

OF OPERATING EXPERIENCE . . .. . . ...... ii

1. Annual Personnel Exposure and Monitoring Report . .1 I
2. Changes, Tests, and Experiments . . ............ . . .......... . . .... .4 I

I I

I

'I

'I I

I I

I I

i I

I

I INTRODUCTION The 1996 Annual Report for Trojan Nuclear Plant is submitted in accordance with the requirements of Possession Only License NPF-1, Appendix A, Permanently Defueled Technical Specification 5.8.1 and 10 CFR 50.59(b)(2).

SUMMARY

OF OPERATING EXPERIENCE IN 1996 I Throughout the entire year, the plant remained permanently shutdown with the fuel removed from the reactor vessel.

I I

I I

I I

I i

I I

I ii l l I - - - - -

E I 1. ANNUAL PERSONNEL EXPOSURE AND MONITORING REPORT Reauirement Trojan Possession Only License NPF-1, Appendix A, Permanently Defueled Technical Specification 5.8.1.1, requires that an annual report be submitted which includes:

" Occupational Radiation Exposure Report shall include a tabulation on an annual basis of the number of station, utility, and other personnel (including contractors) receiving exposures I > 100 mrem /yr and their associated man-rem exposure according to work and job functions (e.g., fuel handling, surveillance, I maintenance and waste processing). This tabulation supplements the requirements of 10 CFR 20.22006. The dose assignments to various duty functions may be estimated based on pocket I dosimeter, thermoluminescent dosimeter (TLD), or film badge measurements. Small exposures totaling < 20% of the individual total dos;: need not be accounted for. In the aggregate, at least 80%

I of the total whole body dose received from extemal sources should be assigned to specific major work functions."

I Report Table 1 lists the number of workers receiving total exposures greater than 100 mrem per year and the total exposures by work and job function for the year 1996 based on self-reading dosimeter results. The " Total" and " Grand Total" sections of the table are based on self-reading dosimeters.

All work performed for dismantlement and decommissioning was class!Oed as work I function "Special Maintenance." All of the contractors for dismantleme:it and decommissioning activities were classified asjob function " Maintenance." Note that I contracted personnel represented 61% of exposed workers and 85% of 19% reported dose.

I I

I I '

I I

I TABLE 1 Sheet 1 of 2 REPORT ON NUMBER OF PERSONNEL AND MAN-REM I BY WORK AND JOB FUNCTIONS 1996 i No. of Personnel (>100 mrem)

Station Utility Contract Station Total Man-Rem Utility Contract Work and Job Function Emnlovees Emnlovees Workers Emnlovees Fmolovees Workers REACTOR OPERATIONS & SURVEILLANCE I Maintenance Personnel Operating Personnel 11ealth Physics Personnel 0

0 0

0 0

0 0

0 0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 I Supervisory Personnel Engineering Personnel 0

0 0

0 0

0 0.00 0.00 0.00 0.00 0.00 0.00 ROUTINE MAINTENANCE & INSERVICE INSPECTION Maintenance Personnel 0 0 0 0.00 0.00 0.00 I Operating Personnel llealth Physics Personnel Supervisory Personnel 0

2 0

0 0

0 0

0 0

0.00 0.351 0.00 0.00 0.00 0.00 0.00 0.00 0.00 I Engineering Personnel 0 0 0 0.00 0.00 0.00 SPECIAL MAINTENANCE Maintenance Personnel 0 4 35 0.00 0.589 37.775 Operating Personnel 0 0 0 0.00 0.00 0.00 I Ilealth Physics Personnel Supervisory Personnel Engineering Personnel 0

3 10 0 0

0 0

0 0

4.222 0.00 0.562 0.00 0.00 0.00 0.00 0.00 0.00 I WASTE PROCESSING I Maintenance Personnel Operating Personael licalth Physics Personnel 4

0 0

0 0

0 0

0 1

0.809 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.118 I

Supervisory Personnel 0 0 0 0.00 0.00 0.00 Engineering Personnel 0 0 0 0.00 0.00 0.00 lI i l I

I I TABLEI I Sheet 2 of 2 l

I REPORT ON NUMBER OF PERSONNEL AND MAN-REM BY WORK AND JOB FUNCTIONS 1996 1

l No. of Personnel P100 mrem) Total Man-Rem .

Station Utility Contract Station Utility Contract i Work and Job Function Emnlovees Emniovees I

Workers Emnlovees Emnlos ees Workers REFUELING I Maintenance Personnel Operating Personnel Chemistry & Radiation 0

0 0

0 0

0 0

0 0

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 l

I Control Personnel Supervisory Personnel Engineering Personnel 0

0 0

0 0

0 0.00 0.00 0.00 0.00 0.00 0.00 l

I TOTAL Maintenance Personnel 4 4 35 0.809 0.589 37.775 Operating Personnel 0 0 0 0.00 0.00 0.00 Health Physics Personnel 12 0 4.573 0.00 0.118 I

1 l Supervisory Personnel 0 0 0 0.00 0.00 0.00 Engineering Personnel 3 0 0 0.562 0.00 0.00 GRAND TOTAL 19 4 36 5.944 0.589 37.893 I

I I

II l

I 3 l I

I

2. CHANGES. TESTS. AND EXPERIMENTS Requirement Federal Regulation 10 CFR 50.59 requires:

"(a)(1) The holder of a license...may (i) make changes in the facility as described in the safety analysis report. (ii) make changes in the procedures as described in the safety analysis report, and (iii) cenduct tests or experiments not described in the safety analysis report, without prior Commission approval, unless the proposed change, test or experiment involves a change in the technical specifications incorporated in the license or unreviewed safety question.

(b)(2) The licensee shall submit...a repe t cor.taining a brief description of any changes, tests, and experiments, including a summary of the safety evaluation of each... annually.. "

Report Section 2 of the Annual Report provides a description of changes, tests, and experiments completed in 1996 in accordance with 10 CFR 50.59 and a summary of the supporting safety evaluation.

L 4

f Y

(

l 199610 CFR 50.59 Annual Report i

Safety Evaluation Number 94-021 1 Subiect Revision to PGE-1012, " Fire Protection Plan," Table 3.9-1 1 Drscription of Chance. Test. Erneriment PGE-1012 " Fire Protection Plan," Table 3.9-1, was revised to add the National Fire Protection i Association (NFPA) Code Deviations. This Safety Evaluation (SE) was previously reported in PGE-1015-94. However, the SE was revised and the changes incorporated in the revision g necessitate additional reporting. The SE is associated with a periodic update to the Fire l Protection Program indicating NFPA code deviations on Table 3.9-1 of PGE-1012. The changes to PGE-1012 were determined to reduce probability of a fire occurring at Trojan.

Summary of Safety Evaluation Criteria in Operating License Amendment 192 were addressed to ensure the safe storage of l irradiated fuel relative to a fire, and to not increase the likelihood of a release of radioactive I materials from a fire. These changes to PGE-1012 are administrative in nature and do not significantly impact the initiating variables of any accident scenario evaluated in the DSAR.

These changes do not affect any plant equipment or the processes and ; rocedures for responding I to an equipment malfimetion. These changes do not create the possibihty of an accident or malfunction ofequipment different from those evaluated in the DSAR. The changes do not reduce the margin of safety as defined in the Trojan Technical Specifications or Bases.

Therefore, these administrative changes were determined to not involve an unreviewed safety question because. (i) there was no increase in the probability of occurrence of the consequences of an accident or nalfunction of equipment important to safety previously evaluated in the DSAR,(2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR. was not created, and (3) the margin of safety as defined in the basis for I any technical specifications was not reduced.

1 I

l i

I s L

199610 CFR 50.59 Annual Report Safctv Evaluation Number 95-007 i Sublect System 16, " Component Cooling Water," Deactivation Plan Description of Chance. Test. Experiment The System 16 deactivation plan reduces Component Cooling Water System (CCWS) extraneous i CCWS loads and wetted piping and deactivating flow to unnecessary equipment. It isolates CCWS flow to equipment and components no longer needed, or no longer required, in the permanently defueled and shut down condition of the plant. It also de-energizes components I associated with this deactivated equipment. This safety evaluation encompasses System 16 deactivation plan changes to Defueled Safety Analysis Report (DSAR), Figure 3.3-2, in which deactivated components in extraneous CCWS flowpaths are represented generically as I " miscellaneous equipment." DSAR, Figure 3.3-2, was changed to accurately reflect the CCWS as it is in the present plant condition.

I Summarv of Safety Evaluation Isolating deacti';ated equipment in extraneous flowpaths in the CCWS does not represent an unreviewed safety question. The only remaining function of the CCWS is to provide cooling water for rem (, val of heat from the spent fuel pool. The System 16 deactivation plan does not g isolate or de-energire any equipment necessary to perform this function. The CCWS is classified l as "available" and there are no longer any applicable Trojan Technical Specifications associated with this system and the CCWS no longer performs any safety functions. While this work is not quality or safety related, the CCWS does perform a function "important to the safe storage of I irradiated fuel." The CCWS cools the Spent Fuel Pool (SFP) heat exchangers. The changes associated with the System 16 deactivation plan do not degrade the ability of the CCWS to

[ provide adequate cooling water flow to the SFP heat exchangers. The changes associated with I the deactivation plan do not increase the probability of occurrence of an accident, and the consequences of an accident are bounded by the DSAR. The changes do not increase the probability, or consequences of, a malfunction of equipment important to safety, nor do they create the possibility of an accident or equipment malfunction different than any evaluated in the DSAR. The changes do not reduce the margin of safety as defined in the Technical Specifications or bases. It was concluded that the changes do not involve an unreviewed safety question.

1 1

1 I e l _

1 199610 CFR 50.59 Annual Report Safety Evaluation Number 95-053 I Subiect i Revision to PGE-1017, " Trojan Security Plan" I Description of Chance. Test. Faperiment I

j I Administrative changes were made to the Trojan Security Plan that include revised management titles and an organization chart. References to the Training and Qualification Plan were changed to include the full title," Trojan Nuclear Plant Security Force Training and Qualification Plan."

l l

Other administrative changes include incorporating Oregon Administrative Rule 345-26-340,

" Security Plans for Nuclear Installations,"into PGE-1017, Section 12.1.3, along with some ,

editorial changes.

l I Summarv of Safety Evaluation l

l The changes made to PGE-1017 are administrative in nature and do not affect the initiatmg '

variables of any accident scenario evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These

{

changes are not associated with plant equipment design, operation, or maintenance and will not '

result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases.

Therefore, these administrative changes do not involve an unreviewed safety question because, i (1) there is no increase in the probability of occurrence or the consequences of an accident or l malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is I not created, and (3) the margin of safety as defined in the basis of any technical specifications is not reduced.

l I '

I I

I 7

I

199610 CFR 50.59 Annual Report Safetv Evaluation Number 95-054 Subiect Defueled Plant Modification Request (DPMR)95-015, Detailed Construction Package (DCP) 1 -

Install Smaller Capacity Service and Instrument Air Compressor Descrintion of Chance. Test. Erneriment This DPMR installs a smaller capacity air compressor to reduce house electrical load. The modifications made by this DPMR do not change any radiological, environmental, or effluent monitoring equipment and procedures. Changes were made to the DSAR to remove detail I indicating the method by which the air compressor is cooled. The changes do not affect the function or contribution made by the compressor.

l Summarv of Safety Evaluatioji This modification reduces the house electrical load, but does not impact the function of ongoing plant systems. The interface of the instrument air system is unchanged by this modification so I there is no possibility of an accident of a different type than any already evaluated in the DSAR.

The addition of this new compressor does not increase the probability ofloss ofinstrument air because the new compressor is a altemate source of air and is independent of water cooling, nor does it increase the consequences of such an. accident because instrument air is unavailable. The instrument air system interface whh oystems containing equipment important to safety does not change with this modification, therefore the processes and procedures for responding to an l equipment malfunction are unchanged. Therefore, this modification does not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a diffeient type then any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in I the basis for any technical specifications is not reduced.

I I

I I 8 M

l 1

199610 CFR 50.59 Annual Report Safety Evaluation Number 95-060 Subiect DPMR 95-012, DCP 1 - Mechanical Disconnection of Emergency Diesel Generators from Plant Systems l

Description of Chance. Test. Experiment The modification replaced isolation valves formerly used to isolate the Senice Water piping.

Summary of Safety Evaluation I The Service Water System function is not changed. The installation of blind flanges to provide Service Water isolation does not involve any unreviewed safety questions. Affected equipment I is not required to support safe operation of the plant or safe storage ofirradiated fuel. This is required since the Service Water System is described in sufficient detail in the DSAR to be affected by the choice of Senice Water isolation locations. The changes do not affect the I initiating variables of any accident scenario evaluated in the DSAR. Affected equipment is not required to support the safe operation of the plant in the permanently defueled condition or the safe storage ofirradiated fuel. These changes do not affect the processes and procedures for l responding to an equipment malfunction. This modification does not result in any degradation in the reliability of structures, systems, or components, and do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these changes do not involve and unreviewed safety question because (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than I

any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for nay technical specifications is not reduced.

I I

I li l

9

_--___a

E I

199610 CFR 50.59 Annual Report Safety Evaluation Number 95-061

I Subiect l DPMP.95-012, DCP 2 - Electrical Disconnection of the Emergency Diesel Generators (EDGs)

Description of Chance. Test. Experiment g DPMR 95-012, DCP 2, is the electrical portion of the modification to disconnect the EDGs from I g plant systems to allow for removal and sale. All equipment disconnected by DCP 2 is covered l under previously reported safety evaluations with the exception of the Emergency Battery Lights l (EBLs). To allow for removal of the EDGs, some structural steel was removed along with five

I remote EBL heads.

l Summarv of Safety Evaluation The EDGs were previously deactivated under the System 24 deactivation plan. The EBLs do not interface directly or indirectly with any equipment important to safety. The EBLs are not required to operate the EDGs and are only required for emergency egress. Therefore, this modification does not involve an unreviewed safety question because,(1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR,(2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

I 3

I I

I I

10

'E I

199610 CFR 50.59 Annual Report Safety Evaluation Number 95-063 i

Subiect '

System 94 Deactivation Plan - Deactivate the 500 Foot Meteorological Tower Instrumentation Descrintion of Chance. Test. Experiment l I This modification was performed to deactivate the unneeded 500' meteorological tower instrumentation. The 33' meteorological tower instruments will not be deactivated at this time.

l l

l I Summarv of Safety Evaluation Defueled Safety Analysis Report, Section 2. " Site Characteristics," references and describes the meteorological monitoring program at Trojan. The statements are no longer applicable in the shutdown and defueled condition. The meteorological instruments were no longer required with l

Amendment 11 to PGE-1021,"Off-Site Dose Calculation Manual." Instruments are no longer '

required to provide real time meteorological data for the assessment of the consequences of a radiological emergency and a radioactive release. Other compensatory measures are available to measure outside ambient temperature data. PGE-1021 no longer requires the collection of hourly meteorological data. Instead, historical meteorological data is used as a basis for creating default meteorological parameters. References to meteorological instruments and methods of data collection will be changed in the Defueled Safety Analysis Report to be consistent with PGE-1021. These changes do not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or I the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

I I

I i

11 I

I

199610 CFR 50.59 Annual Report Safety Evaluation Number 95-064 Subiect Revision to PGE-1060, " Permanently Defueled Emergency Plan (PDEP)"

Description of Chance. Test. Experiment Appendix A, Page 5-1, was changed to reflect the requirement change from the Shift Manager and an operator not being assigned fire brigade duties to only the Shift Manager not being assigned fire brigade duties. A letter of agreement with Professional Communication Services to perform emergency notifications to offsite agencies was added. Several other miscellaneous editorial corrections were made in this revision.

Summarv of Safety Evaluation The changes made by this revision remove an administrative restriction on an on-shift operator from performing fire brigade duties and remove a redundant statement of a regulatory administrative notification. As such, these changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. The basis for the original

, requirement was to ensure a minimum of two persons were available on-shift to perform emergency response actions. The two persons were necessary to perform initial response activities - one to act as the Emergency Coordinator directing emergency response actions, and the other to act as Communicator, who made offsite agency notifications within the required 30 minute period. With the letter of agreement implemented, the operator is no longer needed to perform this task. Consequently, the operator may now be used to perform fire brigade duties, if needed. If the operator is assigned PDEP emergency response responsibilities, they will be prioritized in relation to fire brigade duties by the Emergency Coordinator. This change does not decrease the effectiveness of the PDEP. The procedures implementing notifications required by 10 CFR 50.47(b)(5) are described in Section 6M and are not changed by the revision. Although additional time will be required to initially notify Professional Communication Senices and provide them the emergency information in accordance with 10 CFR 50, Appendix E(IV)(D)(3) and the exemption granted to PGE, less time will be lost in performing the notifications due to the elimination ofinterruptions the operator experiences in responding to urgent plant conditions while trying to complete the notifications. In the event of telephone failure or some other problem that precludes Professional Communication Senices from making the notifications, the back up measures described in PDEP, Section 8.2, remain unchanged. The capability to perform emergency notifications to offsite agencies within 30 minutes is not diminished by the revision.

Additionally, Page 9-2 was changed to remove the requirement to submit changes to the PDEP and the implementing procedures to the NRC and Oregon Department of Energy. These statements are redundant to existing federal and state regulations governing Trojan operations.

The PDEP statements do not affect PDEP effectiveness or impact regulatory compliance, as they are addressed in Trojan Plant Procedure 18-14. These changes are not associated with plant 12

199610 CFR 50.59 Annual Report equipment design, operation, or maintenance and will not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these administrative changes do not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

13

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-001 Subiect Trojan Plant Procedure (TPP) 13-7, Revision 6, " Fire Protection Program" Description of Change. Test. Experiment This procedure revision updated TPP 13-7 to include the Possession Only License changes to PGE-1012," Fire Protection Plan," for Amendment 16. Administrative controls were updated to reficct the current editions of the NFPA Codes, change the fire brigade from 3-man to 2-man, update the transient combustible control program, delete the use of Aqueous Film Forming Foam (AFFF), and to make other editorial changes. Administrative controls related to demolition activities were included in this revision in response to comments incorporated during preparation of the Decommissioning Plan.

Summary of Safety Evaluation These changes are based on the NFPA codes and are intended to further reduce the probability of the occurrence of a fire by ensuring proper handling of explosives, ignition sources, and vehicle fuels during demolition activities. While this procedure change increases the amount of transient combustibles allowed in the plant, it does not increase the probability of occurrence of a significant fire due to the decrease in overall combustible loading in the plant and the reduction ofignition sources and, thus, will not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and will not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these administrative changes do not involve an unreviewed safety question because, (1) there is no increase in the probablity of occurrence or the consequences of an accident or malfunction of equipment imponant to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

14 i .

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-002 Subiect Fire Protection Exemption 96-001, Component Cooling Water (CCW) Heat Exchangers Description of Chance. Test. Experiment This evaluation was performed to support permanent removal of the fire doors, flood barriers, and missile shields associated with the CCW Heat Exchangers.

Summary of Safety EvaluatiDR The DSAR evaluates the loss of forced Spent Fuel Pool cooling accident and states that the only requirement for safe fuel storage is that the level in the pool be maintained. This activity will not increase the consequences of this accident due to a flood, missile damage to the CCW system, or fire. No additional type of malfunction was identified that may be created by this activity for any equipment that is important to safety. The types of malfunctions associated with this activity are limited in that the barriers being deleted were installed to mitigate specific malfunctions that are no longer significant (i.e., fire, flood, and missile impact) for this area. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and will not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these do not involve an unreviewed safety question because, (1) there is no increase in the probabiity of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

15

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-003 Sublect Maintenance Request (MR) 8828 to Remove Knockout Panels Descrintion of Change. Test. Erneriment This MR removed the removable knock-out panels in various pump and heat exchanger rooms to facilitate removal of the components contained in the rooms.

Summary of Safety Evaluation The removable walls in the various pump and heat exchanger rooms are considered to be deactivated since the associated equipment in the rooms have been deactivated. The radiation shielding and flood protection functions formerly supplied by the walls is no longer necessary to support plant operation in the permanently defueled condition. No special tests or experiments are involved with the knock-out panel removal etivnies. Removal of these knock-out panels has no effect on effluent release controls or environmental monitoring requirements. The panels themselves are potentially contaminated, thus their removal constitutes a decommissioning activity. These changes will not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and will not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defmed in the Trojan Technical Specifications or Bases. Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probabiity of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

16

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-008 Subiect Revision to PGE-1012, " Fire Protection Program" Description of Chanee. Test. Experiment These changes update PGE-1012 to reflect the deactivation of EDGs, Jockey Fire Pump, and Diesel Fuel Oil System. The changes also reflect deactivation of un needed fire extinguishers, and removal of Technical Support Center vault Halon Systems. Editorial changes deleted reference to previously deactivated components, as well as other minor changes.

Summarv of Safety Evaluation The changes will not increase the probability of occurrence of an accident prevbusly evaluated in the DSAR. These changes do not affect any plant equipment or ~ a processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and will not result in any degradation in the reliability of structures, systems, or components. These chanF::s do not affect the margin of safety as defined in the Trojan Technical Specifiestien:: cr Bases. Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probabiity of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

17

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-011 Subiect DPMR 96-008, DCP 1 - Clear Northeast Corner of Site for the Proposed Independent Spent Fuel Storage Installation (ISFSI)

Description of Change. Test. Experiment Structures in the nonheast corner of the site were removed to prepare for construction of the ISFSI. One fire hydrant was also removed.

Summarv of Safety Evaluation This safety evaluation is required because of references to the Radwaste Storage Building in PGE-1012," Fire Protection Plan." PGE-1012 is referenced in the DSAR for the Fire Protection Program. None of the accidents identified in the DSAR are applicable to radwaste in the Radwaste Storage Building or the transfer of radwaste from one building to the other. Radwaste is stored in the Condensate Demineralizer Building, which precludes any affect on equipment important to safety. Because the location of radwaste on the plant site is external to the areas and systems applicable to accidents, these changes do not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and will not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probabiity of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evluated previously in the DS.sR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

18 l

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-015 Subiect DPMR 96-002, DCP 4 - Deccnmission the 'B' Containment Spray Pump Room Description of Change. Test. Experiment This DCP removed a smoke detector and contaminated equipment from the 'B' Containment Spray Pump (CSP) Room.

Summary of Safety Evaluation The equipment removed is no longer required to support the operation of the plant in the permanently defueled condition, or to support the safe storage or irradiated fuel. No equipment important to safety is affected by the activities associated with this DCP. The removal of the smoke detector does not involve an unreviewed safety question. Essentially no combustible loading remains in the room, and adjacent detectors for the corridor remain in service. Localized

" hot work" in the room is covered by plant administrative procedures and a fire watch. These changes will not increase the probability of occurrence of an accident previously evaluated in the DSAR. Removal of the smoke detector was performed in conjunction with removal of the radioactive components from the room, thus negating the possibility of generating significant airbome radioactivity due to a fire.1hese changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and will not result in any degradation in the reliabGity of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. The makeup flow path to the SFP and SFP cooling are not affected. Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probabiity of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

19 l

l

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-019 Subiect Revision to PGE-1057," Certified Fuel Handler (CFH) Training and Re-Training Program" Description of Change. Test. Experiment PGE-1057 was revised to allow a Certified Fuel Handler candidate to maintain CFH certification without standing proficiency watches. This revision is contingent on the candidate maintaining all other retraining requirements current and the candidate not assuming any CFH duties until the proficiency watch requirement is satisfied.

Summary of Safety Evaluation This change involves the retraining requirements of Certified Fuel Handlers. The change is administrative in nature and does not authorize or permit any changes in the way the plant equipment is designed, maintained, or operated. These changes will not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction.

These changes are not associated with plant equipment design, operation, or maintenance and will not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these changes do not involve an unreviewed safety question because,(1) there is no increase in the probabiity of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

20

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-021 Subiect DPMR 96-001, DCP 2 - Modification of the 93 Foot Fuel Building Decontamination Shop and Associated Equipment ,

Description of Chance. Test. Experiment To make room for decommissioning activities on the 93 foot elevation of the Fuel Building, the Decontamination Room was modified. The equipment and stored items are removed from the area, as are the spray booth and sinks. The modification includes removing three high voltage smoke detectors, the spray booth tumtable, fan and filter, ice vest freezer, ultrasonic tanks, '

associated demineralizer water piping, and drain piping.

Summary of Safety Evaluation The ultrasonic decontamination equipment in the Decontamination Shop was not active for many years and the area was primarily used for storage of contaminated materials. The smoke detectors were ionization type not suitable for the high particulate environment that is created during decontamination activities in the room. The room typically has a very low combustible loading. These changes do not increase the probability of occurrence of an accident previously evaluated in the DSAR. The existing administrative controls for use of equipment in this area prevents this activity from threatening safe storage of fuel. The activities described in this DCP do not impact make up flowpath to the SFP. The level of fire hazard in the area is ultimately reduced due to the removal of materials stored in this room. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

21

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-023 Subiect Replace Halon Fire Extinguishers in Containment Description of Chance. Tert. Experiment The Halon fire extinguishers in Containment were replaced with less expensive, equivalent dry chemical extinguishers.

Summarv of Safety Evaluation The use of Halon extinguishers was specified in Containment due to concerns over the effects of dry chemical powders on critical stainless steel piping. With the plant permanently defueled, thi, is no longer a concern. The type of fire that can be expected in Containment under today's conditions would be a Class A fire in transient combustibles. This type of fire can be effectively extinguished with a dry chemical extinguisher. The fire extinguishers are rated as equivalent units by NFPA-10, therefore, their ability to fight a fire is the same, and the consequences of a fire are not increased. The equipment impacted by this modification is limited to the area of Containment and would not directly impact the SFP or its support systems. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and will not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

22

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-028 Subject DPMR 96-012, DCP 1 - Deactivate and Disconnect Miscellaneous Loads for Asset Recovery Description of Change. Test. Experiment DPMR 96-012, DCP 1, is the electrical portion of the modification that made an opening in the Emergency Diesel Generator (EDG) Room to allow removal of the EDGs for sale by Asset Recovery. All previously deactivated equipment was being removed under a Maintenance Request. This DCP removed one unit heater, speakers in sound-proof booths, two area speakers, a sound-powered phone, and an Emergency Battery Light (EBL).

Summarv of Safety Evaluation Since the size of the opening is larger than the original plan, several additional miscellaneous loads require deactivation. Only the EBL requires a change to a drawing referenced in PGE-1012, " Fire Protection Plan," which is included by reference as part of the DSAR. The EBLs are not required to operate the EDGs and are now only required for emergency egress, therefore, will not increase the probability of occurrence of an accident previously evaluated in the DSAR. The EBLs do not interface directly or indirectly with any equipment important to safety and, as such, do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and will not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR,(2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

23 l

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-029 Subiect Revision to PGE-1061, " Trojan Nuclear Plant Decommissioning Plan" Description of Chanee. Test. Experiment The Decommissioning Plan, Section 3.2.6, was revised in a manner which will make it consistent with the DSAR. Specifically, reference to a condenser R meter and a set of standardized ionization chamber thimbles were deleted from the text. A statement was added to allow establishing temporary exit points as remote radiologically controlled areas.

Summary of Safety Evaluatian The condenser R meter is typically used to calibrate a gamma calibrator. Readings are taken and sent offsite where a qualified vendor creates calibration curves for the plant's use. Condenser R meters are no longer used, instead a qualified vendor comes onsite and performs the calibration readings and develops curves. Therefore, the listing in the Decommissioning Plan stating that condenser R meters are used is not necessary. The statement being added to Section 3.2.6.3.3 is a modification made to the Decommissioning Plan consistent with the DSAR. The statement allows establishment of temporary exit points at remote controlled areas to allow frisking personnel to determine if they have been contaminated. These changes are administrative in nature and do not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and will not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as d: fined in the basis for any technical specifications is not reduced.

24

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-033 Subiect DPMR 96-012, DCP 2 - Deactivate and Remove Deluge Systems #3,4, and 5 to Support Removing Transformers Description of Change. Test. Experiment The main and auxiliary transformers were removed. To support this removal it was necessary to deactivate and remove Deluge Systems #3 (protected main transformer X-02), #4 (protected auxiliary transformer X-03), and #5 (protected auxiliary transformer X-03). The hazard protected against in each case was a fire in the oil inside the transformers.

Summarv of Safety Evaluation The deluge systems were not in a radiologically controlled area. They were well-removed from the spent fuel pool area and its support systems and, therefore, removal does not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment

. malfunction important to safety. These changes are not associated with plant equipment design, operation, or maintenance and will not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for eny technical specifications is not reduced.

25

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-035 Sublect DPMR 96-003, DCP 3 - Decommission the Positive Displacement Charging Pump (PDP) Room Description of Change. Test. Experiment Contaminated equipment was removed from the PDP Room. Some non-radiologically contaminated equipment was also removed.

Summary of Safety Evaluation This safety evaluation is required due to the removal of the room smoke detector, which is described in PGE-1012. " Fire Protection Plan." The detector was removed in conjunction with radioactive components to support removing contaminated components and piping. PGE-1012 was revised to indicate the change. The Defueled Safety Analysis Report does not describe any of the affected equipment. These changes will not increase the probability of occurrence of an accident previously evaluated in the DSAR. Equipment in the affected room is no longer required to support plant operation in the permanently defueled condition and does not support the safe storage ofirradiated fuel. Essentially no combustible loading remained in the room and adjacent detectors for the corridor remain in service. Localized " hot work"in the room is performed using plant administrative procedures and a fire watch. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and will not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

26

l 199610 CFR 50.59 Annual Report Safety Evaluation Number 96-036 Subiect DSAR Revision to Add Exception to Compliance with Regulatory Guide 1.39 Description of Change. Test. Experiment Table 3-5.1 was revised to allow using controls other than those specified in RG 1.39,

" Housekeeping Requirements for Water-Cooled Nuclear Power Plants." Specifically, it omitted the requirement for a written material control log for controlling material above the spent fuel pool. However, the option for using a log is not precluded. If a log, for control of materials, is not used, a visual inspection of the tops of spent fuel assemblies is performed.

Summary of Safety Evaluation In DSAR Table 3-5.1, Trojan committed to compliance with the requirements of RG 1.39, which endorses the application of the recommendations of American National Standards Institute (ANSI) Standard N45.2.3," Housekeeping During the Construction Phase of Nuclear Power Plants." ANSI Standard, Section 2.1," Planning," requires a written record of the entry and exit of material be established and maintained for Zone III cleanliness areas. In addition, Section 3.2,

" Control of Facilities," states that appropriate control measures be provided through using such items as log books and tethered tools. Because the plant no longer operates and has a relatively long time available to respond to and mitigate the consequences of any accident postulated in the DSAR, strict application of the requirements of ANSI N45.2.3 was no longer necessary. The use of a log for control material above the spent fuel pool is no longer required, but the option for its use is not precluded. If a log for control of materials is not used, a visual inspection of the tops of spent fuel assemblies is to be performed. These changes do not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction.

These changes are not associated with plant equipment design, operation, or maintenance and will not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these changes do not involve an unreviewed safety question because,(1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

27 i

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-039 Subiect Revision to PGE-1057, " Trojan Security Plan," to incorporate Biometric Hand Geometry System Description of Chance. Test. Experiment PGE-1017 was revised to incorporate biometric hand geometry system requirements.

Summarv of Safety Evaluation The biometric hand geometry system is an enhancement to the Industrial Area access control system. The system does not interface with any other plant equipment and does not affect the operation, maintenance, or design of any equipment important to safety. These changes do not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and will not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than a

any evaluated previously in the DSAR is not created, and (3) the margin of safety as dermed in the basis for any technical specifications is not reduced.

28

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-040 Subiect Revision to DSAR to add an Exception to Compliaace with Regulatory Guide (RG) 1.88 Description of Change. Test. Experiment DSAR, Table 3-5.1, was revised to incorporate the use of optical storage devices for retaining Quality Assurance records. The optical disk storage medium is used for protection and retention of records in addition to silver Halide film.

Summary of Safety Evaluation This is an administrative change only. In DSAR Table 3-5.1, Trojan committed to compliance with RG 1.88, which endorses the application of the recommendations of ANSI Standard N45.2.9, " Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants." Use of this storage media was addressed and endorsed in Nuclear Regulatory Commission (NRC) Generic Letter 88-17, " Plant Record Storage on Optical Disks."

This administrative change does not authorize or permit any changes in the way the plant equipment is designed, maintained, or operated. Therefore, it does not increase the probability of occurrence of an accident previously evaluated in the DSAR. This change does not affect any plant equipment or the processes and procedures for responding to an equipment malfunction.

This change is not associated with plant equipment design, operation, or maintenance and does not result in any degradation in the reliability of structures, systems, or components. This change does not affect the margin of safety as defined in the Trojan Technical Specifications or Bases.

Therefore, this change does not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

29

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-041 Subiect DSAR Revision to Reflect Operation Shift Change from 8 Hours to 12 Hours Description of Change. Test. Experiment This change to the DSAR reflects a longer time between operator rounds as a result of schedule changes from 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shifts to 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts. Specifically, DSAR Section 3.3.2.3, " Design Evaluation," for Spent Fuel Pool Cooling System description was changed.

Summary of Safety Evaluation This is an administrative change to reflect existing shift schedules. Operator shift schedule is not an initiator for any accidents described in the DSAR. This change does not increase the probability of occurrence of an accident previously evaluated in the DSAR. The DSAR change is bounded by the accident scenarios described in the DSAR. This change does not affect any plant equipment or the processes and piocedures for responding to an equipment malfunction. The change is not associated with plant equipment design, operation, or maintenance and does not result in any degradation in the reliability of structures, systems, or components. The change does not affect the margin of safety as defined in the Trojan Technical Specifications or Bases.

Therefore, the change does not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is nct created, and (3) the margin of safety as defined in the basis for any technical specifications is riot reduced.

30

199610 CFR 50.59 Annual Report Saferv Evaluation Number 96-042 Subject Correction to Table 4.1-1 of the DSAR Description of Chance. Test. Experiment DSAR, Table 4.1-1, was changed to correct the designations of the Triaxial Peak Accelerographs (TPA) for seismic monitoring.

Summarv of Safety Evaluation DPMR 95-012, DCP 5, authorized moving the TPA in the West Emergency Diesel Generator (EDG) room to prevent it from being damaged as a result of removing the EDGs. As part of the review process it was discovered that the alpha sub designator did not agree with the number of the instrument in the field. This safety evaluation supports the administrative correction to the DSAR Table 4.1-1. These changes are administrative in nature. There is no equipment important to safety associated with seismic monitoring. The changes do not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design. operation, or maintenance and do not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

31

4 199610 CFR 50.59 Annual Report Safety Evaluation Number 96-044 Sub_icet System 94 Deactivation Plan and Lowering of the Meteorological (Met) Tower Descrintion of Change. Test. Experiment The top 320 feet of the 500 foot Met tower was removed.

Summary of Safety Evaluation The instrumentation on the Met tower was previously deactivated. The existence of a 500 foot Met tower is depicted on Figure 3-2 of PGE-1060, " Permanently Defueled Emergency Plan," as a location reference only. The Met tower is not described or discussed elsewhere in PGE-1060 for use in response to any plant emergency. Removal of the top 320 feet of the 500 foot meteorological tower will leave a tower structure of I80 feet tall. The tower was purchased by PGE Corporate ofDee for lease to outside communications companies for personal communication services antennas. The instmmentation on the Met tower was previously deactivated (reference SE 95-063). These changes will not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect the processes or procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and will not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Speci6 cations or Bases. Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR,(2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

32

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-046 Subiect DPMR 96-017, DCP 3 - Spent Fuel Pool Bridge Crane Modification Description of Chanee. Test. Experiment The cantilevered section of the spent fuel pool bridge crane, which extends east over the new fuel storage area / room, was removed. The DSAR, and PGE-1037," Spent Fuel Storage Rack Replacement Report," were revised to reflect removal of the cantilevered arm.

Summary of Safety Evaluation This modification was necessary to position equipment necessary for the Spent Fuel Pool Debris Project. Removal of this section does not affect the safe operation of the plant and is not required for the safe storage ofirradiated fuel. It is not credited in the DSAR toward the mitigation of any accidents. The activity does not affect or degrade any fuel handling design safety features or decay heat removal capability. A worst case drop analysis was performed for the work which resulted in an impact energy on the spent fuel pool racks below the specified Technical Specification limit. Administrative controls are in place to control this work.

Therefore, these changes do not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect the processes and procedures for responding to an equipment malfunction. These changes do not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. The change does not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

33 l

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-047 Subiect DSAR Revision Concerning Fuel Building Crane Mechanical Stops and Electrical Limit Switches Description of Chance. Test. Experiment Changes were made tc the DSAR, Sections 3.2, " Spent Fuel Storage," and 4.2, " Fuel Handling,"

to clarify the discussion of the Fuel Building crane mechanical stops and limit switches. The changes add the provision that the mechanical stops and electrical limit switches may only be bypassed or removed while following an approved procedure, and then only with the Shift Manager's approval. Clarification was made to state that heavy load movement outside the cask movement envelope shown in Figure 4.2-2 is allowed when following an approved procedure and then only with the Shift Manager's approval.

Summarv of Safety Evaluation Clarification concerning the use of the Fuel Building crane in the vicinity of the spent fuel pool is consistent with PGE's commitment to the NRC in a letter dated Januay 22,1982, " Control of Heavy Loads, NUREG-0612," which states, "The Fuel Building crane has mechanical stops and electrical interlocks which prevent movement of the hook centerline closer than 6 ft to the spent fuel pool. These protective devices may only be bypassea or removed while following an approved procedure, and then only with the Shift Supervisor's approval." This change allows removing the mechanical stops and electrical limit switches for the Fuel Building crane for specific projects, provided approval is received from the Shift Manager, and then only while following an approved procedure. All other provisions of NUREG-0612 continue to be in effect.

These changes will not increase the probability of occurrence of an accident previously <. maated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and will not result in any degradation in the reliability of structures, systems, or components. These changes do not afTect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these changes do not involve an unreviewed saray question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment imponant to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

34

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-048 Subleet Revision to PGE-1017," Trojan Security Plan" Dfscription of Chance. Test. Experimini This revision incorporated changes after completion of DPMR 96-014 that constructed and opening in the North wall of the Auxiliary Building and installed a door over the opening.

Security instrumentation was installed on the new door. PGE-1017, Trojan Security Plan," was revised to incorporate the changes.

Summary of Safety Evaluation The affected wall is part of the Protected Area Boundary. These changes will not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment me. function. These changes do not result in any degradation in the reliability of ,tructures, sy,tems, or components. These changes do not affect the margin of safety as defined in the

~

rojan Technical Specifications or Bases. Therefore, these changes do not involve an t

unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

35

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-049 Subiect DPMR 96-017, DCP 1 - Modify the Fuel Building Bridge Crane Description of Change. Test. Experiment This DCP modified the Fuel Building bridge crane to attach a dedicated hoist for use during the Spent Fuel Pool Debris Project. The modification provides an attachment point (s) for a dedicated hoist. The safety evaluation screening also evaluates moving the bridge crane over the spent fuel pool to verify the extent of the travel area covered by the dedicated hoist attachment point (s). This required that limit switches and mechanical stops be temporarily disabled for the duration of the travel area verification. After the verification was performed, the limit switches and mechanical stops were restored.

Summary of Safety Evaluation Administrative controls provide protection while moving the bridge crane over the spent fuel pool. These changes do not increase the probability of occurrence of an accident previously evaluated in the DSAR. Any possible accidents associated with this activity are bounded by those described in the DSAR. These changes do not affect the processes and procedures for responding to an equipment malfunction. These changes do not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

36

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-050 Sub_iect DPMR 96-018, DCP 1 -Install Prefilter to the Inlet of the Containment Purge System Description of Change. Test. Experiment This DPMR installed an additional prefilter on the Containment purge exhaust inlet inside Containment. The additional prefilter consists of 22 medium efficiency (85%) filters on a set of frames which will be bolted to the existing Containment Purge exhaust opening inside containment.

Summarv of Safety Evaluation The new prefilters have a much higher efficiency than the existing prefilter. The filter elements remove more of the particulates that were passing through the existing prefilter and loading the HEPA filters. The new prefilter is part of a system which has no safety significance and no impact on any systems or components important to safety, therefore, this change does not increase the probability of occurrence of an accident previously evaluated in the DSAR. This change does not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. This change does not result in any degradation in the reliability of structures, systems, or components. The change does not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, the change does not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR,(2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

37

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-052 Subleet Revision to PGE-1057," Certified Fuel Handler Training and Retraining Program" Description of Chance. Test. Experiment The changes to the program allow a Certified Fuel Handler to be qualified for Fuel Movement Only. The Fuel Movement Only Certified Fuel handlers are only allowed to direct and supervise nuclear fuel movements and not allowed to perform shift functions. The program for qualifying a candidate as a Fuel Movement Only Certified Fuel Handler parallels the program for the Shift Manager, but only covers requirements directly related to fuel movement functions as delineated in Plant Support Procedure 22-4 and the associated qualification card.

Summarv of Safety Evaluation These changes are administrative in nature and do not authorize or permit any changes in the way the plant equipment is designed, maintained, or operated. The training parallels that of Shift managers and, as such, does not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and will not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probability o r occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

38

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-053 Subiect Revision to PGE-1012," Fire Protection Plan," for Plant Design and Administrative Changes Description of Chance. Test. Experiment Fire Protection procedure, FP-902, wa , revised to reflect the latest combustible loading estimate s

results. The Radwaste Storage Building, located in the Northeast comer of the plant, was removed to support installing the proposed Independent Spent Fuel Storage Installation. The equipment in the Demineralizer Building was removed and the structure designated as a controlled Radwaste Storage Building. PGE-1012, Table 3.1-1, was revised and re-instated to show the required fire barriers previously shown on Figures 3.1-1 through 3.1-4. Other existing tables in PGE-1012 and in the program implementing procedures list the supplementary information that was contained on the deleted figures. A fire extinguisher type and location was changed. Operating specifications for areas in the plant where the fire hazard is reduced to insignificant levels were revised. The Fire Protection Device Action Statement was changed to a more restrictive requirement. Editorial changes corrected titles, removed items missed in a prior revision, deleted text discussion of deactivated components or systems, and corrected typographical errors.

Summary of Safety Evaluation The revision to reflect the latest combustible loading estimate results reflects the reduced overall fire risk in the plan. Relocating radwaste storage to the Demineralizer Building is more conservative because the location is more remote from the site area boundary than the original site. This building is an improvement for fire protection as it is constructed of concrete and has hose stations available inside the structure for manual fire suppression. The change in fire extinguisher type and location are based on NFPA-10 code requirements and do not represent a reduction in the scope of the program. The revision to the applicability of the operating specifications for areas in the plant where the fire hazard has been reduced to insignificant levels is a reduction in scope of the program because it allows the Shift Manager to reduce the level of compensatory measures applied to these areas during an action statement. This is acceptable to the program because, with an insignificant combustible loading, the loss of a fire protection feature will not change the conclusions of the Fire Hazards Analysis in PGE-1012 Section 4.0, that a fire within the area will not impact the safe storage ofirradiated fuel and will not lead to a release of radioactim material in excess of site aret boendary limits due to a fire. Relocation of reference doc ments related to fire protection to tab?es does not represent a significant change in the progru or program controls due to administratin controls for implementing procedures.

The more restrictive Fire Protection Device Action Statcuicnt is not a reduction in scope. The action statement and Table 3.8-1 were developed band on the prctection of specific safety-related equipment. Because this equipment is no longer safety-related, the minimum number of 39

199610 CFR 50.59 Annual Report active detectors required in the table is no longer realistic, justified by the overall reduction in plant combustible loading and the reduction of the consequences of a fire. These changes do not increase the probability of occurrence of an accident previously evaluated in the DSAR. The probability of a fire occurring in the plant is decreased due to the removal and deactimtion of additional equipment. These changes do not result in any degradation in the relia %

structures, systems, or components. These changes do not affect the margin of sa Le e iefined in the Trojan Technical Specifications or Bases. Therefore, these changes do not invosve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

40

199610 CFH 50.59 Annual Report Safety Evaluation Number 96-054 Subkd Maint nance Request 9349 to Remove the Reactor Coolant Pumps (RCPs)

. Description of Chanee. Test. Experiment The reactor coolant pumps were removed.

Summary of Safety Evaluation The RCPs were previously deactivated and disconnected from plant piping systems. Neither their removal or the timing of the removal has any impact on the probability of occurrence of, or consequences from, any accident evaluated in the DSAR. RCP removal is described in PGE-1016, " Trojan Decommissioning Plan." However, the timing of the RCP removal is not specifically described to occur in the Transition Period of plant decommissioning. This safety evaluation was performed to address RCP removal during the Transition Period. The Decommissioning Plan changes more clearly indicate that dismantlement activities can occur during the Transition Period as long as they do not affect the capability for wet storage of spent fuel. RCP removal activities have no impact on the safe storage or irradiated fuel.

Administrative controls exist to control movement of heavy loads in the vicinity of the spent fuel pool. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes do not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR,(2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

41

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-055 Sublect Revision to Radiation Protection Procedure, RP 301, " Radioactive Waste Control and Handling" Description of Chance. Test. Experiment The provision for providing a Special Report to the Commission for Sealed Source Leakage was removed from RP 301, " Radioactive Source Control and Handling."

Summary of Safety Evaluation Approved License Amendment 194 removed the provision for Seal Source Leakage LCO/ Surveillance and Special Reporting from Trojan Technical Specifications. Leakage, testing, and record keeping are unaffected by deleting Special Reporting from RP 301. These changes are administrative in nature and do not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and will not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

42

199610 CFR 50.59 Annual Report S fety Evaluation Number 96-056 Subiect DSAR Revision to Designate Equipment Location Drawings as Historical Information Description of Chance. Test. Experiment This revision to DSAR, Figures 3.2-15 through 3.2-22 (equipment location drawings), added a note to designate them as " historical information only."

Summary of Safety Evaluation The figures are referenced in DSAR, Section 3.2.1.2, which describes what the Control-Auxiliary-Fuel (C-A-F) Building complex structures were designed to support, and are included in the DSAR for general information. The figures provide a description of equipment location and general plant layout for the operating plant condition. Updating these figures to reflect removed equipment does not alter the original design basis for the C-A-F complex.

Equipment on the figures is currently being deactivated, decommissioned, or removed in conformance with the Trojan Decom;nissioning Plan, PGE-1061. These changes are administrative in nature and do not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and will not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

43

199610 CFR 50,59 Annual Report Safety Evaluation Number 96-059 Sublect Revision 1 to Trojan Plant Procedure, TPP 14-22," Control Building Modification Through-Bolt Surveillance" Description of Change. Test. Experiment This revision removes the requirement to perform the Control Building modification through-bolt surveillance every five years and requires that performance of the surveillance be considered following any seismic event of operating basis earthquake or greater. A historical statement was added to include the surveillance frequency grace period allowed by Trojan Technical Specification Surveillance Requirement, SR 3.0.2.

Summarv of Safety Evaluation Paragraph 2.10 (2.9 in Revision 1) requires that a safety evaluation be performed whenever certain sections, in this case Section 2.6, is revised. This change also adds a historical statement to include the surveillance frequency grace period allowed by PDTS SR 3.0.2. The DSAR currently notes that a through-bolt surveillance program was previously employed. Current Technical Specification, TS 5.7.2.9, requires a through-bolt structural adequacy monitoring program, and TPP 14-22 implements the monitoring program. Through bolts tie reinforced concrete and steel places to the east and west walls of the Control Building. During plant operation, Technical Specification 3/4.7.11 required surveillance of the through-bolt tension and physical condition to be performed at the end of six months and one, two, and five years after initial tensioning, and at five year intervals thereafter. In addition, beginning with the third year surveillance, trend analyses were required in order to evaluate time-dependent through-bolt tension performance. Trojan Calculation, TC-695, demonstrated that the structural adequacy of the Control Building through-bolts will be maintained throughout the remainder of the expected plant lifetime without further field evaluation. This ensures the integrity of the Fuel-Auxiliary-Control Building complex is maintained. These changes do not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction.

These changes are not associated with plant equipment design, operation, or maintenance and will not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

44

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-060 Subiect Topical Report Revisions to Delete References to the Emergency Diesel Generators (EDGs) and Diesel Fuel Oil (DFO) Storage Tanks; Reclassify a Portion of the Service Water System; and Update the Spent Fuel Pool Heat-Up Times Description of Chance. Test. Experiment Changes were made to the DSAR, PGE-1060, " Permanently Defueled Emergency Plan," PGE-1061," Decommissioning Plan," PGE-1012 " Fire Protection Plan," PGE-1062," Supplement Environmental Report," and PGE-1052," Quality-Related List Classification Criteria." The changes included deleting references to the EDGs and DFO storage tanks, which were removed from the plant during 1996. A portion of the Service Water System, which provides a make-up flow path to the spent fuel pool was reclassified from Seismic Category (SC)-I to SC-II. Spent fuel pool heat-up times were updated to a three and one half years after shutdown time frame.

Summarv of Safety Evaluation The requirements for the EDGs and associated DFO storage tanks were previously removed from the license with implementation of License Amendment 190, dated May 5,1993. The Amendment removed the requirement to maintain the Service Water Systems as SC-I. Over three and one halfyears has elapsed since the last time the fuel was taken critical, greatly reducing it's heat output capability. The time frame reference is used to demonstrate the relatively safe state of the fuel in accident conditions at this time, compared to when the plant was operating. This change is based on Revision 4 to Calculation TC-720 (November 12,1996).

This revision to the calculation is based on the table developed in the previous revisions that predicts the decay of the heat output capability of the fuel over time. These changes are administrative in nature and do not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation. or maintenance and will not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

45

199610 CFR 50.59 Annual Report Safety Evaluation Number 96-062 Subiect Revision to PGE-1061, Trojan Decommissioning Plan Description of Chance. Test. Experiment PGE-1061, " Trojan Decommissioning Plan," was revised to reflect the Final Decommissioning Rule and to clarify actions permitted during the Transition Period.

Summarv of Safety Evaluation The proposed change is administrative in nature to clarify descriptions of the activities that can be performed during the Transition Period. The activities do not have an adverse impact on the safe storage ofirradiated fuel or on cost or schedule milestones in the Decommissioning Plan.

Administrative controls remain in effect to control movement of heavy loads in the vicinity of the spent fuel pool. The probability of, or consequences from, decommissioning events is unafrected since the same criteria and methodologies currently described in the Decommissioning Plan are used for Transition Period activities. These changes do not affect any plant equipment or the processes and procedures for responding to an equipmen! malfunction because the changes specifically ensure that equipment important to the safe storage ofirradiated fuel is maintained. These changes are na associated with plant equipment design. operation, or maintent.nce and will not result in t.ny degradation in the reliability of structures, !ystems, or components. These changes do nc,t affect the margin of safety as defined in the Frojan Technical Specifications or Bases. Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a passibility for an accident or malftmetion of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

46