ML20138L190

Reactor Vessel & Internals Removal Plan

ML20138L190
Person / Time
Site:	Trojan  File:Portland General Electric icon.png
Issue date:	01/30/1997
From:	PORTLAND GENERAL ELECTRIC CO.
To:
Shared Package
ML20138L182	List: ML20138L179 ML20138L190
References
PROC-970130, NUDOCS 9702210135
Download: ML20138L190 (36)

Text

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Reactor Vessel And Internals Removal Plan i

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January 30,1997 Trojan Nuclear Plant l Portland General Electric Company

Portland, Oregon l

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Prepared by

Reviewed by: e Approved by: 4 -

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9702210135 970130

ADOCK 0500 4

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• TROJAN REACTOR VESSEL AND INTERNALS REMOVAL PLAN TABLE OF CONTENTS Section and Title Page

1. INTROD UCTI ON . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 l.1 CURRENT DECOMMISSIONING PLAN REQUIREMENTS . . . . . . . . . . 1-1

1.2 DESCRIPTION

OF PROPOSED CHANGE . . . . . . . . . . . . . . . . . . . . . . . . 1-1 1.3 REASON FOR CHANGE .... . ... ...... ................... 1-2 1.4 STATE PROVI S IO NS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 -3

2. PROJECT DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 2.1 REACTOR VESSEL DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 ,

2.2 MAJOR PROJECT ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2 2.2.1 Polar Crane Preparation . . . . . ...... ..................... 2-2 2.2.2 Interference Removal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2 2.2.3 Containment Opening .. . .... .. . .... .. .......... 2-2 2.2.4 Package Preparation . . . . . . .. .... .. ... .. .. ...... 2-2 2.2.5 Removal From Containment . . . . . . . . . . . .................2-3 2.2.6 Preparation For Shipping . . .......... . . . . . . . . . . . . . . . . 2 -3 2.2.7 Transportation . . . . . . . . . ........... ... . .. ......... . 2-3 2.2.7.1 Trojan Site Transit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-3 2.2.7.2 Columbia River Transit ...........................2-4 2.2.7.3 Port of Benton to US Ecology Transit . . . . . . . . . . . .. . 2-4 -

2.2.8 Final Plant Configuration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-5

3. S AFETY EVALUATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 -1 3.1 IMPACT ON RESPONSE TO EXTERNAL EVENTS IN DSAR . . . . . 3-1 3.1.1 Explosions . . . . . . . . . . . . . . . . . . ........................ . 3-1 3.1.2 Toxic Chemicals . . . . . . . . . . . . . . . . . . . . . . . . ......... ... 3-2 3.1.3 Fires . .......................... ... ............... 3-2 3.1.4 Ship Collisions with the Intake Structure . . . . . . ...... ....... 3-2 3.1.5 Corrosive Liquid Spills on the River ... ........ ... ....... 3-2 3.1.6 Cooling Tower Collapse . . . . . . ...... ............... . .. 3-3 3.1.7 Earthquakes . . ...............................3-3 3.1.8 High Winds and Tornado . . . . . . . . . . . . . . . ......... . .. . 3-3 3.1.9 Flooding . ...... ........ ........... ... .. ..... .. 3-3 3.1.10 Volcanic Activities . . . . . . . . . . . . .... . ...... ........ 3-4 3.2 IMPACT ON RESPONSE TO ACCIDENTS IN DSAR . . . . . . . . . . . . . 3-4 3.2.1 Radioactive Release From a Subsystem or Component . . . . . . . . . . 3-4 3.2.2 Fuel Handling Accident . . . . . . . . . . . . . . . ....... . . . . 3-4 3.2.3 Loss of Spent Fuel Decay Heat Removal Capability . .. ... .. 3-5 3.3 IMPACT ON EQUIPMENT IMPORTANT TO SAFETY IN DSAR . . . . . 3-5 3.4 IMPACT ON SAFETY MARGIN BASIS FOR TECHNICAL SPECIFICATIONS . . . . . . . . . . . . ............ . ....... ... . 3-6 1

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l TROJAN REACTOR VESSEL AND INTERNALS REMOVAL PLAN  :

TABLE OF CONTENTS I i

Section and Title Page 1

3.5 CONCLU SIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 -6  ;

3.6 REFERENCES

. . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 -6 i

4. ENVIRONMENTAL EVALUATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1 4.1 EFFECT ON HUMAN ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1 l 4.2 EFFECTS ON TERRAIN, VEGETATION, AND WILDLIFE . . . . . . . . . . 4-1 ,

4.3 EFFECTS ON ADJACENT WATERS AND AQUATIC LIFE . . . . . . . . . . 4-1

. 4.4 EFFECTS OF RELEASED RADIOACTIVE MATERIALS . . . . . . . . . . . 4-2  :

i 4.5 EFFECTS OF RELEASED CHEMICAL AND SANITARY WASTES . . . 4-2 i

4.6 EFFECTS ON RADIATION EXPOSURE TO THE PUBLIC . . . . . . . . . . . 4-2

5. PERMANENTLY DEFUELED EMERGENCY PLAN . . . . . . . . . . . . . . . . . . . . . . . . 5-1 5.1 EFFECTIVENESS OF THE PDEP .............................. 5-1 5.2 CRITERIA OF OAR 3 45-26-3 5 0 . . . . . . . . . . . . ............... .... 5-1 1 6. S EC URITY PLAN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6- 1 .

6.1 DEFUELED CONDITION SECURITY PLAN EFFECTS . . . . . . . . . . . . 6-1 6.2 10 CFR 50.54 AND OAR 345 B ASIS . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1 ,

7. QUALITY ASSURANCE PROGRAM . . . . . . . .. . . . . . . . . ................. 7-1

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8. DECOMMISSIONING PLAN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-1 8.1 DECOMMISSIONING EVENTS DESCRIBED IN SECTION 3.4 OF

. DECOMMIS SIONING PLAN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-1 ,

8.1.1 Decommissioning Activity Event . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-1

, 8.1.1.1 Decontamination . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-2 8.1.1.2 Dismantlement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-2 8.1.1.3 Materials Handling Events . . . . . . . . . . . . . . . . . . . . 8-2 8.1.2 Loss of Support Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-2 8.1.3 Internal Events . . . . ..............................8-3 8.1.3.1 Fire Events ............................8-3 8.1.3.2 Explosion Events . . . . .. ......... ..... 8-3 8.1.4 External Events . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-3 8.2 RELEASING SITE FOR UNRESTRICTED USE . . . . . . . . . . . . . . . . . . . 8-3 8.3 DECOMMISSIONING COSTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-4 8.3.1 Adverse Impact ou Availability of Funds to Complete Radiological Decommissioning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ........ 8-4 8.3.2 Increase or Decrease Decommissioning Costs by Greater than 10%

of Previous Estimation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-4 8.4 EFFECTS ON ENVIRONMENT NOT PREVIOUSLY CONSIDERED ii

TROJAN REACTOR VESSEL AND INTERNALS REMOVAL PLAN TABLE OF CONTENTS .

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Section and Title Page l l

IN TROJAN ENVIRONMENTAL REPORT . . . . . . . . . . . . . . . . . . . . . . . 8-4 8.5 CRITERIA FOR FREE RELEASE OF MATERIALS . . . . . . . . . . . . . . . . . 8-4 8.6 METHODOLOGY FOR DETERMINING BACKGROUND RADIATION LEVELS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-4 8.7 PROVISIONS MADE FOR HAZARDOUS OR RADIOACTIVE WASTE MATERIAL REMOVAL ...................................... 8-5

, 8.8 TYPES OR AMOUNTS OF EFFLUENTS THAT MAY BE RELEASED OFFS ITE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8- 5 8.9 RADIOLOGICAL OR HAZARDOUS MATERIAL EXPOSURE TO SITE WORKERS OR MEMBERS OF THE PUBLIC . . . . . . . . . . . . . . . 8-5

9. FIRE PROTECTION PLAN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9-1 l 9.1 SAFE STORAGE OF IRRADIATED FUEL ..... .. . ............ 9-1 l 9.2 RELEASE OF RADIOACTIVE MATERIALS DURING A FIRE IN CONTAINMENT . . . . . . . . . . . . . ... ..... . ................ 9-1

. 9.3 EXCEPTIONS TO NFPA CODES AND STANDARDS NOTED IN THE

. FIRE PROTECTION PROGRAM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9-2 9.3.1 Fire Protection Equipment ............................ ... 9-2 9.3.2 Smoke Detection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9-2 9.3.3 Fire Barriers .. .. ...... ..... .. ..... .......... 9-2 i

9.3.4 Administrative Requirements . . . . . . . . . ................... 9-2

10. RADIOLOGICAL ENVIRONMENTAL AND EFFLUENT MONITORING . . . . . . . 10-1 iii i

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. REACTOR VESSEL AND INTERNALS REMOVAL MAN i

l. INTRODUCTION i

The purpose of this Reactor Vessel and Internals Removal (RVAIR) Plan is to provide a ,

description and analysis of the proposed change to the Trojan Decommissioning Plan associated i with RVAIR activities for Oregon Energy Facility Siting Council (EFSC) review and approval in accordance with Oregon Administrative Rule (OAR) 345-26-370(4). This section provides (1) a ,

' description of the current Trojan Decommissioning Plan mquirements, (2) a description of the j proposed change associated with RVAIR activitie::, (3) a discussion of the mason for the change, and (4) a discussion of the regulatory requimments of OAR 345-26-370(2) & (3), which provide '

the acceptance criteria for EFSC appmval of the decommissioning plan, and how these criteria .

[ are satisfied by RVAIR activities.

[ 1.1 CURRENT DECOMMISSIONING PLAN REQUIREMENTS {

Revision 0 of the Trojan Decommissioning Plan (PGE-1061) describes the separate removal of j the mactor vessel and ie reactor vessel internals. The Plan provides for the internals to be i removed from the reactor vessel and segmented. Segmentation of the internals would be

! performed underwater in the reactor cavity and would require several plant modifications.to support the activity. After completion of these modifications, the reactor cavity and transfer i canal would be flooded to allow the segmentation process to begin.

l Segmented portions of the internals that am clast.ified as greater than Class C waste would be

stored in containers fabricated to standard fuel assembly size and initially stored in the spent fuel c- racks in the spent fuel pool. This waste would eventually be transferred to the Independent Spent

Fuel Storage Installation (ISFSI) for storage until a federally approved facility is available. ,

Segmented portions of the internals that are classified as low level radioactive waste and are suitable for near surface burial would be packaged and shipped to the US Ecology disposal l facility near Richland, Washington. Radioactive waste is classified per 10 CFR 61.55.

! The Decommissioning Plan provides for the reactor vessel to be removed intact or sectioned. If

removed intact, the vessel would serve as its own shipping container or possibly require

- certification as an exclusive-use shipping container for transporting the vessel. The upper head

would also be disposed of intact or sectioned. If the upper head were disposed of intact, a cover i plate would be installed over the bottom flange. Based on the neutron activation analysis, the reactor vessel and upper head would be packaged and shipped to the US Ecology disposal facility near Richland, Washington.

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1.2 DESCRIPTION

OF PROPOSED CHANGE The proposed change to the Decommissioning Plan adds the RVAIR option as a means of removing and disposing of the reactor vessel and the reactor vessel internals. The RVAIR option involves leaving the reactor internals in the reactor vessel, removing the reactor vessel with the

' . internals and upper head intact, packaging the vessel for shipment, and disposing of the package at the US Ecology disposal facility near Richland, Washington.

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REACTOR VESSEL ANDINTERNALS REMOl'AL PLAN The activities associated with the RVAIR option are similar to those of the Large Component Removal (LCR) project completed by PGE in November 1995. Prior to removal from containment, the reactor vessel with the internals intact will be lifted from its present vertical position and lowered to a horizontal position. It will be prepared as a shipping package in accordance with the requirements of Title 10, Code of Federal Regulations (10 CFR) Part 71, " Packaging and Transportation of Radioactive Material." These preparations include placing low-density cellular concrete (LDCC) inside the reactor vessel, welding closures on openings, and welding shielding on external surfaces as neccssary. The LDCC will serve to fix internal radioactive contamination and provide additional shielding. The reactor vessel will be removed through an opening in the south face of the containment building. The opening, created during the LCR project, will be enlarged to accommodate the reactor vessel.

The reactor vessel package (RVP) will be moved out of containment and lowered onto a multi-wheeled transporter using a specially constructed lift system. The RVP wili be tied down to the transporter and moved to the Trojan barge slip. The tied down RVP and transporter will be loaded as an integral unit onto a barge and tied down. The barge will transport the loaded transporter from the Trojan barge slip to the Port of Benton in Washington via the Columbia River. The transporter with the RVP will be moved off the barge to the US Ecology facility on the Hanford Reservation, where the RVP will be removed from the transporter and disposed.

l 1.3 REASON FOR CHANGE i

The RVAIR option for dispond crie reactor vessel and internals is being considered because it offers numerous advantages over the option currently described in the Decommissioning Plan. These advantages are discussed below.

The RVAIR option considers the reactor vessel and internals to be one component for the purpose of waste burial classification. Using the guidance provided in the NRC's " Branch Technical Position on Concentration Averaging and Encapsulation," the RVP is classified as Class C waste and can thus be disposed of at the US Ecology disposal facility. Therefore, no greater than Class C waste results from this option. The waste volume projection for the reactor vessel, internals, and installed shielding, disposed of under the RVAIR option is 8341 ft' of Class C. The option to separately dispose of the reactor vessel and internals results in a waste projection of 13,236 ft' of Class A waste,231 ft' of Class B waste,4,513 ft' of Class C waste, and 340 ft' of greater than Class C waste. Thus the RVAIR option results in less total projected waste volume.

In addition, the occupational radiation cxposure for the RVAIR option is estimated to be 67.1 person- j rem. The estimated exposure currently in the Decommissioning Plan for the separate removal of the  ;

reactor vessel and internals is 85 person-rem (50 person-rem for the reactor vessel internals removal j and 35 person-rem for the reactor vessel removal). Therefore, the estimated occupational radiation exposures for the RVAIR option is less than that for the separate removal option.

Finally, the RVAIR option involves only one radioactive waste shipment whereas the separate removal option involves a minimum of 45 shipments (assuming shipment of the reactor vessel in one piece).

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REACTOR VESSEL AND INTERNALS REMOVAL PLAN l

l PGE has estimated the radiation exposure to the general public for the single RVAIR shipment to be l 0.111 rem. This is less than the general public exposure estimate of 1.539 rem for the multiple shipments required for the separate removal option.

l l.4 STATE PROVISIONS On June 28,1994, the State of Oregon issued new rules governing nuclear decommissioning activities.

Specifically, OAR 345-26-370(2) & (3) included the criteria by which EFSC would evaluate the acceptability of a proposed decommissioning plan. PGE submitted the proposed Trojan Decommissioning Plan for EFSC review and approval on January 26,1995. On March 14,1996, EFSC issued an order approving the Trojan Decommissioning Plan.

I The RVAIR project described previously represents a change to the currently approved Trojan Decommissioning Plan. OAR 345-26-370(4) specifies the criteria for determining whether a change represents a significant revision to the Decommissioning Plan, which would thus require prior EFSC

( review and approval. As discussed in Section 8.7 of this plan, activities associated with the RVAIR i project do involve a significant change as defined in OAR 345-26-370(4), and therefore, EFSC approval is required prior to implementation.

This section evaluates the RVAIR project against the criteria established in OAR 345-26-370(2) and I l

(3).

OAR 345-26-370(2)(a) i Theplan contains criteriafor thefree release ofmaterials and the area as specifiedin Table I below...

Section 4.2 of the Trojan Decommissioning Plan addresses free release criteria for the Trojan site.

Activities associated with the RVAIR project do not change the limits for loose or fixed surface contamination. The existing criteria will continue to be in effect before, during and after the RVAIR project. Therefore, the conclusions regarding this OAR criterion will not be changed by the performance of the RVAIR project and the criterion is satisfied.

OAR 345-26-370(2)(b)

After decommissioning, the exposure rate at one meterfrom allsurfaces in thefacility buildings and outdoor areas shall be SpR/hr or less above background radiation level Background radiation is definedin OAR HS-01-010.

Section 4.2 of the Trojan Decommissioning Plan addresses free release criteria for the Trojan site.

RVAIR project activities do not change the limits established for direct exposure from radioactivity.

The existing criteria will continue to be in effect before, during, and after the RVAIR project.

Therefore, the conclusions regarding this OAR criterion will not be changed by the performance of the RVAIR project and the criterion is satisfied.

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REACTOR VESSEL AND INTERNALS REMOVAL PLAN OAR 345-26-370(2Vc)

The plan must contain provisions that require removalfmm the site of all radioactive waste as ,

definedin ORS 40.300 on a schedule acceptable to the Council. Spent nuclearfueland other radioactin materials that must be disposed ofin afederally approvedfacility may be stored on the  !

site until such afederally Approvedfacility will take thefuel and these radioactive materials.

As stated previously, the RVAIR project involves the packaging of the reactor vessel with the reactor internals intact and shipment of this package to the US Ecology radioactive waste disposal facility near Richland, Washington. This project satisfies the OAR criteria in that the radioactive waste (i.e.,

reactor vessel and internals) will be removed from the Trojan site. In addition, this project will not ,

adversely impact the schedule currently contained in the Trojan Decommissioning Plan.

It should be noted that performance of the RVAIR project will eliminate segmentation of the reactor vessel internals. This in turn will eliminate the need to store greater than Class C (GTCC) waste at the Independent Spent Fuel Storage Installation (ISFSI) for eventual transfer to a federally approved facility.

For the reasons stated above, PGE concludes that the RVAIR project satisfies the OAR criterion.

OAR 345-26-370(2Vd)

The plan must contain a programfor an acceptable monitoring and controlling effluents to ensure congpliance with applicable state andfederallimits. This program may be incorporated by reference, ifit has previously been cyproved by the department.

The activities associated with RVAIR will not change PGE's program for monitoring and controlling effluents to ensure compliance with applicable state and federal limits. This program is contained in the Offsite Dose Calculation Manual (ODCM) and the Radioactive Efiluent Controls Program, which will not be changed as a result of RVAIR activities. This program was previously approved by the State of Oregon and was incorporated by reference into the Trojan Decommissioning Plan. PGE concludes that this OAR criterion is satisfied.

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QAR 345-26-370(2Ve)

The plan must contain a programfor radiological monitoring to ensure the environment is not being adversely affected. This program may be incorporated by reference ifit has previously been ppproved by the department.

The activities associated with RVAIR will not change PGL's program for radiological monitoring to ensure the environment is not being adversely affected. This program is contained in the ODCM and 1

the Radioactive Efiluent Controls Program, which will not be changed as a result of RVAIR activities.

This program was previously approved by the State of Oregon and was incorporated by reference into the Trojan Decommissioning Plan. PGE concludes that this OAR criterion is satisfied.

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' REACTOR VESSEL ANDINTERNALSREMOVAL PLAN i OAR 345-26-370(2Vf)  ;

The plan must contain provisionsfor removal or connel ofhazardous waste that are consistent i with Applicablefederalandstateregulations. I 1

Section 3.6, Nonradioactive Waste Management, of the Trojan Decommissioning Plan contams provisions for removal or control of hazardous waste that are consistent with applicable federal and  ;

. state regulations. The provisions contained in this section are not changed by performance of the RVAIR project. Nonradioactive hazardous waste generated during the RVAIR project will be i removed or controlled in accordance with the provisions of DP Section 3.6. Therefore, PGE j 4 concludes that the OAR criterion is satisfied. t l OAR 345-26-370(2Wa)

? An analysis ofdecommissioning alternatives shall beprovided with theplan, satisfactory to the  ;

i 1 Council. This analysis will describe the basesfor the decommissioning alternative selected, and shall include a comparison ofSAFSTOR and DECON as those terms are defined by the U.S l Nuclear Regulatory Commission. The analysis must demonstrate that ingpacts topublic health i and safety of the option chosen are bounded by the alternatives analyzed abors The analysis must t i demonstrate that the alternative chosen protects the environment and the health and safety ofthe  !

public consistent with state andfederal statues, rules, and regulations.

I PGE submitted the Decommissioning Alternative Evaluation for the Trojan Nuclear Plant for EFSC f I approval on January 26,1996. This evaluation described the bases for PGE's selection of the DECON  :

, alternative and provides a comparison of DECON and SAFSTOR. The evaluation also demonstrates  !

i that the impacts to public health and safety of DECON are bounded by the alternatives analyzed.  !

Finally, this evaluation demonstrates that the DECON alternative protects the environment and the i

health and safety of the pubhc consistent with state and federal statues, rules and regulations.

i i Activities associated with the RVAIR project will not adversely impact the conclusions of this  !

l evaluation. Removal of the reactor vessel with the internals intact is a decommissioning activity and ,

thus does not alter either the decommissioning alternative chosen (DECON) or the comparison of  :

DECON and SAFSTOR. Likewise, the RVAIR option does not alter the previous conclusion that the l DECON alternative protects the environment and the health and safety of the public consistent with  !

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state and federal statutes, rules and regulations. As discussed in Section 8.9 of this plan, the impacts  ;

of the RVAIR option on public health and safety are bounded by those previously analyzed for the separate removal option.

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I REA CTOR VESSEL AND INTERNAIS REMOVAL PIAN OAR 345-26-370(3)

Theplan must include an estimate offunding necessaryforimplementation. The Councilshall '

determine ifprovisionsforfunding are adequate to implement theplan.

Section 5 of the Trojan Decommissioning Plan provides an estimate of funding necessary for implementation of the Plan. The costs associated with RVAIR activities do not adversely affect this funding estimate. RVAIR activities are estimated to cost approximately $23.8 million as compared to

$38.4 million for the separate removal of the reactor vessel and reactor internals. Hence, the RVAIR option represents a significant cost savings over the cunent option for disposal of the reactor vessel and no additional funding is required.

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REACTOR VESSEL AND INTERNALS REMOVAL PLAN l .

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2. PROJECT DESCRIPTION

The RVAIR project consists of those activities necessary to remove the reactor vessel with the f internals intact from the Trojan Containment Building, prepare the reactor vessel for transport, and  !

ship it to the US Ecology site on the Hanford Reservation in Washington for disposal. These activities i

! will be conducted by PGE and its contractors and are expected t< . = completed in the second quarter l

! of 1998. PGE will maintain overall project management for tF tt%G iroject and is responsible for  ;

integrating the work ofits contractors on individual activities.

2.1 REACTOR VESSEL DESCRIPTION i

The reactor vessel is cylindrical, with a welded hemispherical bottom head and a removable, flanged

and o-ring sealed, hemispherical upper head. The vessel contains internal structures (internals), which provided support for the reactor core and reactor coolant flowpaths during plant operation. Figure 2-i I provides a schematic of the reactor vessel. The reactor vessel is nominally 42'6" long,16' in 3

diameter in the shell region, and 21'10" in diameter at the nozzles. The reactor vessel is fabricated .

from carbon steel with minimum 0.156" thick weld-deposited austenitic stainless steel cladding on the inside wall. The dry weight of the reactor vessel and internals is nominally 634 tons. The vessel may l

! be described as consisting of four regions. A general description of each region including penetrations l is provided below.  :

The upper head is nominally 7'6" high and 17'1" in diameter. The upper head is attached to the shell  !

! flange by 7" diameter studs. The shell flange and head are sealed by two concentric metallic o-rings. l l There are 78 - 4" diameter and 1 - 1" diameter penetrations in the upper head. The minimum wall i i thickness of the base metalis 6.5".

}' t The shell flange, located below the upper head is nominally 30" high and 17'1" in diameter. The

minimum wall thickness of the base metal is 10%".  ;

l The nozzle ring, located below the shell flange, is nominally 8'5%" high and 21'10" at outside  !

diameter. The nozzle ring has four inlet (27.2" 1D) and four outlet (28.8" ID) nozzles in a horizontal  ;

planejust below the vessel flange. The nozzles are spaced evenly around the vessel. Outlet nozzles t are located in adjacent pairs on opposite sides of the vessel. The minimum wall thickness of the base metal is 10%". l' l.

The core ring, located below the nozzle ring, is a cylindrical shell which is nominally 16' in diameter j and 16'6" high. The minimum wall thickness of the base metal is 8%".  !

The bottom head is located below the core ring. The bottom head is nominally 7'10" high and 16' in diameter. The minimum wall thickness of the base metal is 5%". There are 58 - 1%" diameter ,

penetrations in the bottom head. An additional 1%" diameter penetration will be made in the bottom l

head to be used for draining the vessel.

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. REACTOR VESSEL AND INTERNALS REMOVAL PLAN i

2.2 MAJOR PROJECT ACTIVITIES i The purpose of the following sections is to provide a description of the major activities that will be l completed as part of the RVAIR project. Detailed work planning and scheduling for activities will be i completed prior to the commencement of work in the field. Overall, the RVAIR activities will be j similar to those performed during the LCR project. l 2.2.1 Polar Crane Preparation f During the LCR project the containment polar crane was restored to the 400-ton configuration. The l polar crane will not be used to lift the reactor vessel; however, it will be used to move equip. ment j inside containment. To optimize the polar crane capacity and speed for the RVAIR project, it will be  ;

restored to the 165-ton configuration.  !

1 2.2.2 Interference Removal t 1

i Piping and other components attached to the reactor vessel will be severed. These include primary  ;

i j coolant piping, control rod drive mechanisms (CRDMs) and vent line in the top head, and thimble tubes in the bottom head. j i

In addition, concrete structures inside containment will be cut and removed as necessary to provide  !

access for lifting and removing the reactor vessel. l 2.2.3 Containment Opening The reactor vessel will be removed from the containment through the opening cut in the south face of l l the Containment Building during the LCR project. The opening must be enlarged to allow the reactor i vessel and rail system to pass through. This will necessitate removal of additional containment j tendons, cutting and removal of concrete blocks, and alteration of the roll-up door installed over the  !

, opening. The door will be closed when the reactor vessel is being moved, excluding actual movement j of the reactor vessel through the opening, or if there is a likelihood of airborne contamination as a result of other RVAIR activities. When closed, the door will minimize the potential for an '

unmonitored release of radioactive material from containment and will meet the security requirements of 10 CFR 73.55 and the Trojan Security Plan. ,

j- l 2.2.4 Package Preparation ,

Prior to removal from containment, the reactor vessel will be prepared as a shipping package in i accordance with the requirements of Title 10, Code of Federal Regulations (10 CFR) Part 71,  !

j " Packaging and Transportation of Radioactive Material." Studs will be installed, as necessary, in the top head and vessel flange and tensioned. The reactor vessel will be drained and injected with low i density cellular concrete (LDCC).

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, REACTOR VESSEL AND INTERNALSREMOVAL PLAN a

9 Shielding will be installed as required to meet 10 CFR 71 Department of Transportation (DOT)  ;

radiation level limits. Closures will be welded onto all openings. The lining lugs on the upper head will be removed / disabled. The exterior of the vessel will be decontaminated and/or coated as .

i necessary to achieve contamination limits specified in 10 CFR 71 and DOT regulations.  !

! 2.2.5 Removal From Containment ,

i l LiR systems will be constructed and tested inside and outside containment. After the reactor vessel

has been filled with LDCC and attachments severed, it will be lined and downended onto a rail system l l just above the 93' level of Containment. After final package preparations are completed, the RVP will l be moved through the containment opening and lowered onto cradle assemblies attached to the

! transporter.

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2.2.6 Preparation For Shipping  ;

j!

! Prior to shipment, detailed planning will be completed to provide comprehensive project management j

and coordination with appropriate federal, state, and local agencies. This planning effort will include ,

coordination with state agencies responsible for emergency response procedures during transit of the

! RVP between the Trojan site and the US Ecology site on the Hanford reservation. In addition, l required permits will be obtained during this phase.

i  :

The Trojan barge slip will be inspected and silt, rock, and debris will be removed, as necessary, to permit safe access by the barge.

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2 The barge will be inspected by a marine surveyor prior to ballasting and after deballasting at the Trojan barge slip. The inspection will be performed to ensure integrity of the barge. The barge will be classed i by the American Bureau of Shipping, cenificated by the United States Coast Guard (USCG), and j assigned for sole use. The barge loading and unloading procedures will be as specified by a marine i architect.

l The transporter route, onsite and offsite, will be verified as adequate for the required loads by either an engineering evaluation or testing, as appropriate. ,

2.2.7 Transportation

~

Transportation activities are divided into three phases: (1) Trojan Site Transit; (2) Columbia River Transit; and (3) Port of Benton to US Ecology Site Transit.

2.2.7.1 Trojan Site Transit After the RVP is loaded onto the transporter, it will be secured to the transponer by an engineered tie- ,

down system designed to withstand the loads specified in ANSI N14.2, " Proposed American National l Standard Tiedowns for Truck Transport of Radioactive Materials," and 10 CFR 71. The loaded transporter will be inspected to ensure conformance with applicable state and federal standards. Once 2-3 i

REACTOR VESSEL AND INTERNALS REMOVAL PLAN i loaded onto the transporter, the RVP will not be removed from the transporter until it is offloaded into  ;

the disposal trench at the US Ecology site.  ;

The Oregon Public Utility Commission (OPUC) will perform a Commercial Vehicle Safety Alliance l (CVSA) inspection on the loaded transporter and prime mover (s) prior to leaving the Industrial Area. l

]

The loaded transporter will be moved out of the Industrial Area to the barge slip on the Trojan site. i The road to the barge slip is entirely on PGE property. The loaded transporter will then be moved  :

i j onto the barge and secured to the barge by an engineered tie-down system designed to withstand the

loads specified in ANSI N14.24, " Highway Route Controlled Quantities of Radioactive Materials -

j Domestic Barge Transport," and 10 CFR 71.

j The National Cargo Bureau (NCB) and the USCG will evaluate the stowage of the package, and the  :

USCG will inspect the condition of the barge. l

, 2.2.7.2 Columbia River Transit l 3

i The barge will transport the loaded transporter from the barge slip at Trojan to the barge slip at the  !

Port of Benton, Washington, which is approximately 270 miles up nyer.

! The barge will be pushed by a primary tug. A second tug will accompany the primary tug as a backup.  ;

The tugs will meet applicable requirements of 46 CFR Subchapter C, "Uninspected Vessels." The  !

i tugs will be inspected by a marine surveyor prior to departure. The primary and backup tugs will be  !

equipped with dual communication methods and with navigational equipment appropriate for river

]'

navigation per ANSI 14.24 and approved by the USCG. Communication will be established between l the tug and a base station prior to transport. The second tug will provide backup communication.

! The base station will monitor progress of the transport. During transport, the tug will contact the base j station at least once every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. i j

The tug captains will be licensed in accordance with 46 CFR Subchapter B, " Merchant Marine  ;

i Officers and Seamen." PGE radiation protection personnel and a transportation coordinator will i escort the shipment during the barge transit.

l The maximum speed will be 10 knots. At times, slower speeds may be required because oflocal  ;

i conditions, such as traffic. Appropriate safety and security measures will be specified and enforced by  !

the USCG. When moored, appropriate measures will be taken to restrict unauthorized access to the  ;

barge. j i

2.2.7.3 Port of Benton to US Ecology Transit On arrival at the Port of Benton barge slip, the loading process will be reversed. The transporter will l be moved off the barge onto the landing. Prior to departing the Port of Benton property, the  ;

Washington State Patrol may, at its option, perform a Commercial Vehicle Safety Alliance (CVSA) l

< inspection of the loaded transporter and prime movers.

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REA CTOR VESSEL AND INTERNALS REMOVAL PLAN The loaded transporter will be moved overland approximately 30 miles to the US Ecology site at a maximum speed of 5 mph. The hau! route is the same route used to transport the LCR packages. An overload permit will be obtained from local authorities for the overland travel. Escorts will control traffic in the vicinity of the transporter during the entire overland transit. In addition, railroad traffic will be stopped during transit.

Prior to entry at the burial site, the loaded transporter will be inspected for acceptance by US Ecology.

Once inspected and accepted by US Ecology, the transporter will proceed to a prearranged location at the disposal facility. The RVP and support cradles will be offloaded into the disposal trench.

Prior to exiting the US Ecology site, the empty transporter will be inspected by US Ecology and released.

2.2.8 Final Plant Configuration On completion of the RVAIR project, the reactor vessel and internals will have been removed from the containment building. Piping that was cut to allow removal of the reactor vessel will be removed or capped, covered, plugged, or otherwise closed as appropriate. The containment opening door will be maintained in a configuration consistent with 10 CFR 73.55 and the Trojan Security Plan.

Temporary lift systems inside and outside containment will be removed. Other temporary staging and support areas used during the RVAIR activities may be kept for future decommissioning activitics or -

removed if not required.

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REACTOR VESSEL AND INTERNALS REMOVAL PLAN

3. SAFETY EVALUATION

! The conditions under which a license holder may make changes in a nuclear facility are specified in 10 CFR 50.59. A licensee has the authority to make a change without prior NRC approval if the proposed activity does not involve a change to the Technical Specifications or an unreviewed safety 3

question. An unreviewed safety question exists if the probability of occurrence or consequences of a  ;

i previously evaluated accident may be increased, if the possibility for an accident of a different type

- than any evaluated previously may be created, or if the mtrgin of safety as defined in the basis for any Technical Specification is reduced.

The RVAIR activities have been reviewed per the criteria in 10 CFR 50.59, and it has been determined l

j that the proposed activities do not involve a change to the Technical Specifications or an unreviewed safety question. As part of this review, the effects of the RVAIR activities were reviewed with respect to the external events and accident analyses contained in the Defueled Safety Analysis Report (DSAR). The results of these reviews are presented in Section 3. Effects of RVAIR activities on  ;

other PGE Topical Reports were also evaluated during this review and are presented in Sections 4 through 10. ,

i  !

3.1 IMPACT ON RESPONSE TO EXTERNAL EVENTS IN DSAR j The DSAR presents evaluations of the capability of the plant to safely withstand the effects of external events including explosions, toxic chemicals, fires, ship collisions with the intake structure, oil or  ;

corrosive liquid spills on the river, cooling tower collapse, earthquakes, tornados, high winds,  !

flooding, and volcanic activities. It has been determined that the RVAIR activities do not alter plant i response to these external events and thus can be performed in a manner that does not significantly  :

affect occupational or r6lic health and safety.

3.1.1 Explosions

, The effects of potential offsite explosions are unchanged. The ability of structures associated with the

, storage ofirradiated fuel to withstand the atmospheric shock and/or missiles associated with explosions are unchanged since these structures are not being modified or affected by the RVAIR activities. The loading on the Containment building due to an offsite explosion (after the opening in the south face of containment is enlarged) is bounded by the more extreme loads considered in 3.1.7. l Potentially explosive materials (e.g., materials associated with cutting torches and welding equipment) which may be used during the RVAIR activities will be controlled per plant procedures.  ;

[ Once removed from containment, the RVP could be exposed to the effects of an offsite explosion.

However, these effects (atmospheric shock of 2.2 psi and missiles assumed to be less severe than  ;

tornado missiles) will be bounded by analyses performed pursuant to 10 CFR 71 for nonnal conditions l oftransport. i 4

. i 3-1 I

i meroa vessetnowreamisazuovanm t

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As discussed in the DSAR, the very conservative estimates show that the annual probability of a transportation accident near the site involving explosions is less than one in a million. This probability  !

of occurrence of an explosion due to traffic on the river or railroad is not affected by the RVAIR ,

4 activities and is sufficiently low that funher consideration of the explosive effects of a transportation  !

accident on the Trojan site is not warranted.

3.1.2 Toxic Chemicals

. The existing quantities of toxic materials which may still be present on site are not affected by the ,

. RVAIR activities. Plant procedures control the use and handling of any toxic materials (paint,  ;

solvents, scalants, coatings, etc.) that may be required during the RVAIR activities.

As discussed in the DSAR, only offsite storage and nearby transportation of toxic materials pose any  ;

significant threat to on-site personnel. The RVAIR activitica do not change any of the conclusions j associated with the effects ofincidents involving toxic materials. .

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3.1.3 Fires j The potential for adversely affecting the existing Fire Protection Plan as a result of the RVAIR activities is discussed in Section 9 of this plan. It is concluded that the RVAIR activities are within the  ;

i

. provisions of the Fire Protection Plan and plant procedures.

I The DSAR conclusion that off-site fires do not pose a hazard to the site is unchanged by the RVAIR

! activities. '

i j 3.1.4 Ship Collisions with the Intake Structure

The RVAIR activities will involve barge traffic specifically designated for transporting the RVP up the l Columbia River for permanent disposal. This activity will be centered around the Trojan barge slip located at the south end of the site, well away from the intake structure. The intake structure is where j

{ '

the service water system (one of multiple makeup sources to the spent fuel pool) takes its suction.

The number of barge visits to the site is not significant compared to the total ship traffic on the river. l i

l Thus the probability of ship collision with the intake structure is not significantly increased by the RVAIR activities. t i

3.1.5 Corrosive Liquid Spills on the River j i

The DSAR concludes that even with a loss of service water from the intake stmeture due to contamination from oil or corrosive liquids in the river, the safe storage of the fuel will be maintained [

since spent fuel pool make up flow capability is available from other sources. The RVAIR activities l

do not directly involve any oil or potentially corrosive liquids which could result in spills into the river and thus do not affect the DSAR conclusion. >

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_. ... . - _ _ _ _ . . ~ _ . _ . _. -. . . _ _ _ __ ___ _ __- _ - _ _ . _ _ - _ _

I I REACTOR VESSEL AND INTERNALS REMOVAL PLAN

L I 3.1.6 Cooling Tower Collapse if The RVAIR activities do not affect the probability of cooling tower collapse or cne effects of such a i collapse on equipment or systems important to safety as described in the DSAR. The activities are l

primarily located adjacent to containment at sufficient distance from the cooling tower to prevent j damage to the RVP in the event of a collapse.

! 3.1.7 Earthquakes The RVAIR project will use tue coening in the south face of containment, that was constructed during ,

the LCR project, for removal of the u. actor vessel. The opening will be enlarged to fit the larger  :

i diameter RVP. For the LCR project, containment structural integrity was evaluated for the extreme i environmental loading conditions during and after detensioning 100% of the containment tendons.  :

i The evaluation concluded that under bounding environmental loading conditions (Seismic Margin 1 Earthquake [SME]), the Containment Building remained stable and the reinforced concrete and liner ,

plate integrity was maintained both during and after the process of detensioning the tendons and creating the opening. This evaluation bounds the process of enlarging the opening for the RVAIR  :

project since all tendons have already been detensioned and increasing the size of the opening will not affect the evaluation of the containment reinforced concrete and liner plate integrity.  ;

3.1.8 High Winds and Tornado The RVAIR activities will not adversely affect the ability of plant structures to continue to safely store l l

the irradiated fuel in the spent fuel pool. The Fuel Building and equipment associated with the spent fuel pool will continue to withstand wind loadings and tornado missiles as discussed in the DSAR.

t The detensioning and cutting of an opening in the side of containment does not adversely affect the e ability of the structure to withstand tornado forces. The containment opening does provide a path for a tornado generated missile to enter containment since the door will not be designed to withstand l

tornado winds and missiles. However, there is no direct missile path between this opening and the

spent fuel pool or equipment required to maintain spent fuel cooling. Postulated radiological releases i

as a result of breaching the door opening during a tornado or extremely high winds are bounded by

. other analyzed events.

The effect of a postulated tornado missile on the reactor vessel was analyzed (Reference 3.6.1) and l determined that the reactor vessel wall thickness is sufficient to preclude perforation.

3.1.9 Flooding l

Activities associated with the RVAIR project will not be adversely affected by flooding and will not i require separate or unique flood protection. The area where the RVP will be loaded onto the j transporter outside containment is 45 feet above sea level, which is sufficient to be considered safe l 3- from projected floodsc If conditions existed that could lead to flooding, the radioactivity inside the j 3-3

l, REACTOR VESSEL ANDINTERNALSREMOVAL PLAN  ;

J

RVP would be fully contained and remale unaffected by the flood waters, since all openings will have been welded shut prior to removal from cr>ntainment.

3.1.10 Volcanic Activities  !

~

l The DSAR concluded that volcanic activity from the existing volcanic cones in the Cascade Range present a minimal risk to the Trojan Plant. The RVAIR activities have no effect on this conclusion. i i

I 3.2 IMPACT ON RESPONSE TO ACCIDENTS IN DSAR j l Three classifications of accidents for the permanently defueled condition are discussed in the DSAR. )

i These classifications are: (1) radioactive release from a subsystem or component; (2) fuel handling accident; and (3) loss of spent fuel decay heat removal capability. The activities of the RVAIR project  :

were reviewed with respect to each of these classifications of accidents and the results are presented in the remainder of Section 3.2. In addition, the RVAIR activities were reviewed against the

decommissioning events described in the Decommissioning Plan, which is discussed in Section 8.1.

4 3.2.1 Radioactive Release From a Subsystem or Component  ;

Before filling the reactor vessel with LDCC, it will be drained and the resulting radioactive liquid waste will be processed using liquid radioactive waste treatment systems. LDCC will fix internal l surface contamination. The DSAR (6.1) discussion is limited to radioactive releases from the i

radioactive gas waste system and liquid tank failures. As discussed in the Decommissioning Plan (3.3.2), all radioactive gaseous and liquid effluents will be processed in accordance with the ODCM.

. Any potential releases that could result from a material handling event are discussed in Section 8.1.1  ;

j of this plan.

3.2.2 FuelHandling Accident Many of the RVAIR activities are scheduled to take place while fuel is being moved into the ,

4 Independent Spent Fuel Storage Installation (ISFSI). Most of the RVAIR activities will take place  !

inside containment or on the south side of the Containment Building; whereas, the fuel movements will take place in the Fuel Building and between the Fuel Building and the ISFSI located at the northeast corner of the Industrial Area. The opening in the south side of containment will be used for moving i the heavy lift equipment and test weights into and out of containment. Although the equipment hatch adjacent to the spent fuel pool will be used to access containment for personnel and small equipment, i this will have no advera effect on fuel movements since procedures will be in effect to control activities in the area during fuel handling. The RVAIR project will therefore have no effect on the  ;

probability of occurrence or consequences of the fuel handling accident discussed in the DSAR.

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$ 3-4

REACTOR VESSEL AND INTERNALS REMOVAL PLAN

1

3.2.3 Loss of Spent Fuel Decay Heat Removal Capability l According to the DSAR (6.3.1), the only requirement to assure adequate decay heat removal 4- capability is to maintain adequate water level in the spent fuel pool. Normal procedures will assure  ;

that safe load paths will be followed and neither the pool nor cooling /make up to the pool will be affected by RVAIR heavy load handling, which provides the only potential for interaction with the [

spent fuel pool. Therefore, the RVAIR project does not affect the DSAR conclusions.  !

3.3 IMPACT ON EQUIPMENT IMPORTANT TO SAFETY IN DSAR The equipment important to safety evaluated in the DSAR consists of the spent fuel pool, the pool

- storage racks, the fuel transfer tube and structures (i.e., Fuel Building) associated wiht the spent uefl l

pool. As discussed in Section 2 above, the RVAIR activities are primarily located in containment and i

' i the yard area south of containment. There are no safety-related pieces of equipment located in the

! areas where the RVAIR activities will take place.

i t

Use of the containment equipment hatch, which opens into the fuel building, will be required during

several RVAIR activities. Because of the close proximity of the spent fuel pool to the containment equipment hatch, the potential for a load drop into the fuel pool, which could adversely affect the safe i storage of spent fuel was evaluated. l

! The bounding load with respect to the loads expected to be moved through the containment equipment hatch during the RVAIR project is movement of concrete blocks (approximately 56,000 l lbs) to be cut from walls to allow adequate clearance for RVAIR handling inside containment.  !

t The configuration of planned loads is such that there is no potential for a rolling effect as the load is l i

passing through the hatch on the transfer trolley. The shapes are generally rectangular and will be

placed to keep the center of gravity low to minimize the potential for tipping. The loads will be tied or

otherwise secured to the equiprnent hatch transfer trolley as required to ensure adequate stability prior .

l to being transported through the itatch. The transfer trolley and equipment hatch rail system are  !

f j- designed to safely transport loads of up to 100,000 lbs without overturning in the event of an i earthquake.

I Inside the fuel building, the loads will be handled with the fuel building bridge crane in accordance with safe load paths and approved procedural controls. In addition to these safe load paths, f

mechanical stops are provided for the fuel building bridge crane to prevent load movement within 6 feet of the spent fuel pool. l 4

There are no safety-related components within the Fuel Building safe load paths. There will be no '

- load movement over the fuel assemblies in the spent fuel pool associated with RVAIR activities.

Trojan Technical Specifications specify limits for loads carried over the spent fuel pool with fuel  !

7 assemblies stored in the pool. The loads carried over the pool and the heights at which they may be -

carried must be limited in such a way as to preclude impact energies over 240,000 in-lbs if the loads are dropped. The Technical Specifications further require that the potentialimpact energy due to l l

I 3-5 I

REA CTOR VESSEL AND INTERNAIS REMOV4L PLAN dropping the load must be determined to be less than the limit prior to moving each load over racks containing fuel. Compliance will be maintained with this Technical Specification. Therefore, it is concluded that the handling of heavy loads in the Fuel Building will have no adverse effect on the safe storage ofirradiated fuel While not considered safety-related, the service water system is one of the multiple, makeup sources to the spent fuel pool. The service water make up to the spent fuel pool includes the path from the intake structure, buried piping to the Auxiliary / Fuel Buildings and then to the pool. Some transport activities may occur in the yard area which may cross the buried service water piping, but analysis will be performed to ensure the weight is adequately distributed by the transport vehicle such that buried piping will not be affected.

In conclusion, the RVAIR activities will not affect the safety-related structures, systems, or components, and therefore, will not affect any consequences associated with their malfunction.

3.4 IMPACT ON SAFETY MARGIN BASIS FOR TECHNICAL SPECIFICATIONS The Technical Specifications address spent fuel pool water level, boron concentration, temperature, and load restrictions. As discussed above, the RVAIR activities will have no effect on the storage of fuel in the spent fuel pool and thus will have no impact on the safety margin basis for the Technical Specifications.

3.5 CONCLUSION

S It is concluded from the discussion provided in this section that the activities associated with the RVAIR project will have no adverse effects on the storage of fuel in the spent fuel pool and on the capability of the Trojan Nuclear Plant to safely withstand the various accidents and external events discussed in the DSAR.

3.6 REFERENCES

4 3.6.1 PGE Calculation, TC-730, Evaluation of Long Term Tornado Missile Exposure With Regard to Containment Large Component Removal Opening with Roll-Up Door.

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a REACTOR VESSEL ANDINTERNALSREMOVAL PLAN ,

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4. ENVIRONMENTAL EVALUATION 4.1 EFFECT ON HUMAN ACTIVITIES 4

Additional workers will be employed at Trojan during the project. The peak number of workers is  ;

expected to occur during the time (approximately two months) that the reactor vessel is first lifted .

and penetration covers and shielding are welded on. Skilled craft, panicularly welders, will be l j needed. Some of the skilled workers will come from local communities. The largest source of  ;

skilled craft is in the Portland area.

i The Trojan site is in an area that has experienced constmction of several large industrial facilities  !

in addition to the constmetion, operation, and maintenance of Trojan. The maximum number of j on-site workers during the RVAIR project is expected to be significantly less than that for a normal . j refueling outage when the plant was operational. Most of the workers from Portland are expected  ;

to commute, due to the short term nature of the project. No significant adverse impacts are expected on temporary housing or schools as a result of the project.

4.2 EFFECTS ON TERRAIN, VEGETATION, AND WILDLIFE f The RVAIR project will take place on previously developed areas of the site. The reactor vessel will be removed from an existing building and transported on an existing road to the barge slip.  ;

The barge slip area is in a rocky area along the Columbia River, and is adjacent to an  ;

archaeologically significant area where Indian artifacts have been found. Any barge slip dredging  !

will be done in accordance with permit requirements.

Since the project will utilize existing developed areas, no impact is expected to occur on the undeveloped areas. The proposed activities will not affect endangered or threatened species or critical habitat in the vicinity of the site. No changes are needed to :he conclusions reached by PGE on the environmental effects of decommissioning activities in PGE .1063, " Supplement to Applicant's Environmental Report" (Ref: Section 4.2), or to the conclusion: reached by the NRC in the " Environmental Assessment by the U.S. Nuclear Regulatory Commission Related to the Request to Authorize Facility Decommissioning," December 1995 (Ref: Section 2.1.3).  ;

l 4.3 EFFECTS ON ADJACENT WATERS AND AQUATIC LIFE The Reactor Vessel Package will be transported by barge up the Columbia River to the Hanford i

area. Appropriate permits from the US Army Corps of Engineers will be obtained for barge slip dredging as necessary. Required permits will also be obtained for any barge slip modification that  !

may be required. Regarding the potential for radioactive contamination of the water, radioactive ,

shipment regulations require that the package be free of any loose surface contamination. The  !

RVP will be tied down to the transporter, and the transporter tied down to the barge. Tie-down l designs will be reviewed by the appropriate authorities. The reactor vessel nozzles and other penetrations will have covers welded over them, thus minimizing the potential for contamination of adjacent waters and aquatic life.

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REA CTOR VESSEL AND INTERNALS REMOVAL PLAN l

4.4 7FECTS OF RLLEASED RADIOACTIVE MATERIALS l Radioactive gas may be removed from the reactor vessel via venting connection (s) during LDCC ,

filling operations. Radioactive particulate matter will be generated during certain operations of the project such as cutting and grinding. These operations will take place inside the Containment ,

Building. HEPA filters (local and/or Containment Building purge exhaust) will be utilized as ,

necessary. The opening in the Containment Building will be closed when there is a likelihood of airborne contamination. This will minimize the potential for an unmonitored release of gaseous radioactive material. t Regarding the potential for radioactive liquid effluents, the reactor vessel will be drained prior to l filling with LDCC. Any radioactive liquid will be processed as required prior to disposal.  ;

Water is used on the diamond wire saw during concrete cutting operations. Although not expected ,

to be contaminated, the effluent will be' monitored prior to release.

l 4.5 EFFECTS OF RELEASED CHEMICAL AND SANITARY WASTES ,

A small 1 mount of boron may be in water drained from the reactor vessel. In addition, a chemical l foaming agent may be used in the LDCC. Any chemical discharges resulting from the project will be made in accordance with the limitations and conditions of the NPDES Waste Discharge Permit.  !

Regarding sanitary wastes, the Trojan sewage waste treatment plant was placed in service in 1989 and was based on operational staffing levels. The maximum number of workers on-site during the RVAIR project will be less than for a typical refueling-maintenance outage when the plant was operational. Thus there should be no adverse impact on sanitary waste treatment and effluent  !

discharge.

4.6 EFFECTS ON RADIATION EXPOSURE TO THE PUBLIC 4 By the time the vessel leaves the Containment Building, it will be filled with LDCC and have penetration covers and shielding installed. By the time the vessel leaves the site, it will meet the  !

applicable radiation exposure requirements of 10 CFR 71 (NRC) (Sections 71.47 and 71.51), and 49 CFR (DOT) Parts 171 and 172 (categorize hazardous materials), Pan 173 (prescribe requirements for package preparation), and Parts 176 and 177 (prescribe general requirements for i water and land transport, respectively). -

The reactor vessel will be transported by barge to the Richland area. As such, the number of  :

people in close proximity to the package will be significantly less compared to overland shipments.

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't REACTOR VESSEL AND INTERNALS REMOVAL PLAN

5. PERMANENTLY DEFUELED EMERGENCY PLAN f 5.1 EFFECTIVENESS OF THE PDEP The Permanently Defueled Emergency Plan (PDEP) is contained in PGE Topical Report PGE-1060. This plan outlines the actions to be taken in the event of an emergency which could involve a significant release of radioactive material. The plan addresses potential releases from events ,

affecting the fuel in the spent fuel pool, and from fires involving radioactive material.

The removal path for reactor vessel does not go near the spent fuel pool. This eliminates the potential for a heavy load handling accident involving the reactor vessel and the spent fuel pool.

Movement of blocks and weights in order to test ht e reactor vessellifting and lowering devices will i also be controlled to minimize the potential for impact on the spent fuel. Section 8.1.1.3 of this i plan provides a discussion of materials handling events. l Regarding the potential for releases during a fire, plant procedures will be used to control the accumulation of transient combustibles. The reactor vessel contains primarily activated metal and corrosion products, and is not combustible. Section 8.1.3.1 of this plan provides a discussion of ,

l fire events and Section 9 provides a discussion of the Fire Protection Program.

The worst case or bounding accident for the RVAIR project is postulated to be a load handling accident involving the reactor vessel. In order to reduce potential radiation releases resulting from a drop of the reactor vessel, LDCC will be added to the vessel prior to lifting. The LDCC serves to fix internal contamination in-place during movement and transport. The roll-up door over the

opening in the south wall of the Containment Building will be closed while the vessel is being lifted l and down-ended to further reduce the potential for any releases.

Once lowered and tied down to the transporter, the RVP will not be lifted off of the transporter until it reaches the burial ground. This minimizes the potential for releases from an accident outside of the Containment Building. -

Existing Emergency Action Levels in the PDEP address spent fuel pool level, temperature, area radiation levels, and effluent release levels. No accidents have been identified for the RVAIR ,

project which could result in events outside the scope of the PDEP, such as constituting an emergency classification above an Alert. The present provisions of the PDEP are deemed to be adequate to address any events associated with the RVAIR project.

5.2 CRITERIA OF OAR 345-26-350 The RVAIR project does not require a change in Emergency Action Levels. The vast majority of the radioactivity in the RVP is contained in a solid form in the activated metal, as opposed to in a gaseous or liquid form that could be released to the environment in the event of an accident. Shielding will be  ;

attached to the vessel to reduce radiation exposure levels from the activated metal, and to meet 5-1

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, REACTOR VESSEL AND INTERNALSREMOVAL PLAN shipping requirements. The vessel will be filled with LDCC to help fix surface contamination inside the vessel and minimize the potential for a release in the event the vessel were to experience a drop.  ;

To ensure that the maximum dose at the Exclusion Area Boundary is maintained less than or equal to established limits, the amount of radioactive material that would have to be released outside a building to result in a limiting dose of 0.5 rem at the Exclusion Area Boundary cannot exceed 2.07 curies (DP Section 3.4.3.1). The amount of radioactivity associated with the surface area contamination of the ,

reactor vessel and its internals is 155 curies. Using the same assumptions as used in the DP  ;

(3.4.4.3.1), only 0.155 curies would be released, which is bounded by the DP limit of 2.07 curies.

The RVAIR project will require additional personnel to be hired. It will not cause a decrease in the planned staff augmentation capabilities for emergencies, nor will it cause a reduction in the emergency plan requirements for the notification of off-site agencies. Based on the information provided above,  !

no change to the emergency plan is required due to the RVAIR project, and notification to the Energy .

Facility Siting Council is not required per OAR 345-26-350.

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6. SECURITY PLAN ,

The Containment Building is part of the Protected Area. The RVAIR project will involve l enlarging the constmetion opening in the South side of the Containment Building. Compensatory .

actions similar to those used during the Large Component Removal Project will be implemented {

when the opening is being enlarged and during other RVAIR activities, as required.

6.1 DEFUELED CONDITION SECURITY PLAN EFFECTS A change to the Defueled Condition Security Plan (PGE-1017) is required for the RVAIR activities. The change is necessary due to increasing the size of the opening in the Containment Building, which is part of the Protected Area boundary. The opening will be enlarged to j approximately 33' by 33', and it will continue to be a locked and alarmed portal. Compensatory actions, as discussed in the existing Security Plan, will be implemented when required during  :

l RVAIR project activities. This change will not decrease the overall effectiveness of the Security Plan. Upon completion of the RVAIR project, the Containment Building opening will be locked  ;

and alarmed or may be welded shut in a manner which makes it an integral part of the Protected  :

Area barrier. Details and descriptions will be described in the Security Plan.

The RVAIR project will also require the temporary removal of the south gate (old main gate) to the j Industrial Area to allow passage of the Reactor Vessel Package. Compensatory actions will be  !

Implemented in accordance with the currently approved Security Plan. The south gate to the i Industrial Area is neither discussed nor illustrated in the currently approved Security Plan and consequently will not require a Security Plan change. Upon completion of the RVAIR project,  : '

either the old gate will be put back on, or a new gate that meets the applicable requirements for the Industrial Area boundary will be installed.

6.2 10 CFR 50.54 AND OAR 345 BASIS The change to the Security Plan pertaining to the Containment Building opening will be submitted under the provisions of 10 CFR 50.54(p) and OAR 345-26-340, Security Plans for Nuclear Installations. OAR 345-26-340(4) states in part, " Modifications to the plan which do not lessen the effectiveness of the plan may be implemented without prior department concurrence." The change does not require prior NRC or ODOE approval before implementation since it does not decrease the safeguards effectiveness of the plan.

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7. QUALITY ASSURANCE PROGRAM i Written and approved procedures will be required for specified key evolutions such as lifting of the reactor vessel and the installation of penetration closures and shielding. Quality Assurance and Quality Control measures will be in accordance with PGE-8010 and PGE-approved contractor 4 quality assurance project plans. No Changes to PGE-8010 will be required.

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8. DECOMMISSIONING PLAN The Trojan Nuclear Plant Decommissioning Plan (DP) is contained in PGE Topical Report PGE-1061. The DP addresses the decommissioning methodology to be used at Trojan, estimated costs and available funds, major tasks and schedules, and protection of occupational and public health and safety. The DP was submitted for approval to the NRC in accordance with 10 CFR 50.82(b), " Application for termination of license," and to the Oregon Energy Facility Siting Council (EFSC) in accordance with OAR 345-26-370(1).

The Section 2.2.5.3 of the DP curmntly discusses removing of the reactor vessel internals by segmenting them, shipping the disposable portions to the US Ecology disposal facility, and storing j the resulting greater than Class C (GTCC) portions in the Independent Spent Fuel Storage Installation (ISFSI). Section 2.2.5.4 of the DP discusses removing the reactor vessel whole or i

segmented. _ The RVAIR project entails a change to the DP since the internals will remain intact inside the reactor vessel and shipped to the US Ecology disposal site and no GTCC material will be i

generated.

The changes to the DP associated with the RVAIR project do not require NRC approval, since  ;

there are no unreviewed safety questions and no changes to the Technical Specifications involved as demonstrated in Section 3. However, the changes do require approval by the Oregon EFSC i since the changes are deemed significant in accordance with OAR 345-26-370(4). Section 8.7 provides further discussion of the DP changes.

8.1 DECOMMISSIONING EVENTS DESCRIBED IN SECTION 3.4 OF DECOMMISSIONING PLAN Section 3.4 of the Decommissioning Plan presents the results of evaluations and analyses of  :

postulated decommissioning events and evaluates the potential for adverse effects on public health and safety. Events related to decommissioning activities, loss of support systems, fire and '

explosion events, and external events (e.g., earthquakes, tornadoes, etc.) were evaluated. This section of the RVAIR Plan demonstrates that the RVAIR activities will not change the results of the evaluations presented in the DP. ,

8.1.1 Decommissioning Activity Event This section of the DP concludes that the potential consequences of airborne releases of radioactive material bound the potential consequences of releases of contaminated liquids. The types of events that could involve airborne releases were then defined as decommissioning activity events, loss of support system events, fires and explosions, and external events. The effects of the RVAIR project on these events are discussed below.

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! The exterior surface of the reactor vessel will be decontaminated or coated as necessary to meet l transportation requirements. Decontamination processes will be the same as those discussed in the DP (3.4.4.1); therefore, there is no effect on the conclusions reached in the DP.

8.1.1.2 Dismantlement The RVAIR project will involve segmentation of piping and equipment attached to the reactor  ;

vessel and removal of concrete structures in the removal pathway. Because much less segmentation activity is required for the RVAIR project than for the internals segmentation l alternative discussed in the DP, the DP analysis is bounding.  ;

Since the DP (3.4.4.2.2) analysis considers the primary sh ield wall dismantlement as the bounding

- condition and the concrete removal associated with the RVAIR project involves the primary i shield wall, the associated DP conclusion is valid for the RVAIR project.

8.1.1.3 Materials Handling Events l i

To ensure that the maximum dose at the Exclusion Area Boundary is maintained less than or equal to established limits, the amount of radioactive material that would have to be released outside a building to result in a limiting dose of 0.5 rem at the Exclusion Area Boundary cannot exceed 2.07 curies (DP Section 3.4.3.1). The amount of radioactivity associated with the surface area ,

contamination of the reactor vessel and its internals is 155 curies. Using the same assumptions as l used in the DP (3.4.4.3.1), only 0.155 curies would be released, which is bounded by the DP limit of 2.07 curies.

8.1.2 Loss of Support Systems Electric power, cooling water, and compressed air systems provide support to decommissioning activities, including the RVAIR project. Loss of these systems could potentially affect many other systems and plant areas simultaneously. A loss of power will result in the interruption of work activities. In the event of loss of offsite power, work activities with the potential for airborne contamination will be suspended. A loss of cooling water or compressed air do not result in events i

leading to a significant release of radioactive material to the environment during decommissioning activities. ,

Although loss of power is not expected to result in crane or hoists failure, this event would be bounded by the material handling events analyses provided in the DP (3.4.4.3). There is no effect on the conclusions reached in the DP.

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8.1.3 Internal Events 8.1.3.1 Fire Events

. Adequate fire protection features will be maintained through implementation of the fire protection j program discussed in the DP (Section 9), thereby minimizing the potential of occurrence of a fire, j In the DP. (3.4.4.5) it was demonstrated that the worst case fire is assumed to occur in the Low-Izvel Radioactive Waste Storage Building, which is based on the amount of waste generated during decommissioning, work activities, and size of work force. Therefore, there is no effect on the conclusions reached in the DP.

8.1.3.2 Explosion Events

The consequences of the explosion event are bounded by the postulated fire event described in the .

4 DP- 4.4.5).

8.1.4 External Events i

The hazards associated with external events are assumed to be consistent with those that could have

occurred during TNP operation. Such events are of extremely low probability. The associated DP i

-(3.4.4.7) conclusions are valid for the RVAIR project.

During the Large Component Removal Project, the Containment Building was detensioned aid the opening created in the south face was covered by a roll-up door. The requirements for the RVAIR project are such that the Containment Building opening will enlarged to accommodate the Reactor Vessel Package. An evaluation was performed on the Containment Building structural integrity in i this new configuration. It was concluded that under bounding environmental loading conditions,

! - the Containment Building will remain stable and the reinforced concrete and liner plate integrity i will be maintained.

8.2 RELEASING SITE FOR UNRESTRICTED USE Criteria for contamination, exposure, or concentration levels are designed to ensure radioactivity at the site is reduced to acceptable levels that allow unrestricted release of the site. Release of the 2

site, facility, and materials will be based on release criteria for surface contamination, direct

. exposure, and soil and water concentrations consistent with applicable regulations. Tbc criteria and j limits established in the DP are applicable to the entire decommissioning process, and are therefore, applicable to the RVAIR project. Performance of the RVAIR project does not preclude releasing the site for unrestricted use.

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REACTOR VESSEL AND INTERNALS REMOVAL PLAN 8.3 DECOMMISSIONING COSTS 8.3.1 Adverse Impact on Availability of Funds to Complete Radiological Decommissioning The DP describes the option for the separate removal of the reactor vessel and the reactor vessel internals, which is included in the decommissioning cost estimate. The RVAIR project will remove and dispose of the reactor vessel with the internals and the upper head in tact. The cost of the RVAIR project is less than the cost associated with the separate removal of the reactor vessel and the reactor vessel internals. Therefore, the RVAIR project will have no adverse impact on the availability of funds to complete radiological decommissioning.

8.3.2 Increase or Decrease Decommissioning Costs by Greater than 10% of Previous Estimation The projected cost of the RVAIR project is $23,759,000 (1996 NPV) and the projected cost of separate removal of the reactor vessel and the reactor vessel internals is $38,389,000. The projected savings associated with performing the RVAIR project is $14,630,000, which does not

- increase or decrease decommissioning costs by greater than 10% of the estimate in the DP (Table 5.1-1).

8.4 EFFECTS ON ENVIRONMENT NOT PREVIOUSLY CONSIDERED IN TROJAN ENVIRONMENTAL REPORT Performance of the RVAIR project will result in less occupational radiation exposure and less exposure to the public associated with transportation of radioactive waste, than the radiation exposure projected for the separate removal of the reactor vessel and reactor vessel internals.

Therefore, the RVAIR project, which is a part of the decommissioning of the Trojan facility will have no unacceptable impacts on the environment. Environmental effects of decommissioning activities are discussed in Section 4 of PGE-1%3, Environmental Report Supplement - Post Operating License Stage.

8.5 CRITERIA FOR FREE RELEASE OF MATERIALS The criteria and limits established in the DP for unrestricted release of material are applicable to

! the entire decommissioning process, and are therefore, applicable to the RVAIR project.

Consistent with current practice governed by approved plant procedures, equipment, and materials with less than detectable radioactive contamination limits will be unconditionally released.

8.6 - . METHODOLOGY FOR DETERMINING BACKGROUND RADIATION LEVELS The determination of background radiation levels will be performed in accordance with the DP (4.2). The RVAIR project has no effect on the determination of background radiation levels. The RVAIR project supports the overall decommissioning of the Trojan facility by removing

. - radioactive components.

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4 REACTOR VESSEL AND INTERNALS REMOVAL PLAN s

8.7 PROVISIONS MADE FOR HAZARDOUS OR RADIOACTIVE WASTE MATERIAL REMOVAL 4

Revision 0 of the Trojan Deconunissioning Plan describes the separate removal of the reactor vessel and the reactor vessel internals. The DP provides for the internals to be removed from the reactor vessel and segmented. Segmented portions of the internals that are classified as greater than Class C waste would be stored in containers fabricated to standard fuel assembly size and

, initially stored in the spent fuel racks in the spent fuel pool. This waste would eventually be transferred to the Independent Spent Fuel Storage Installation (ISFSI) for storage until a federally approved facility is available. Segmented portions of the internals that are classified as low level radioactive waste and are suitable for near surface burial would be packaged and shipped to the US Ecology disposal facility near Richland, Washington.

The Decommissioning Plan provides for the reactor vessel to be removed intact or sectioned. If removed intact, the vessel would serve as its own shipping container or possibly require a

l certification as an exclusive-use shipping container for transporting the vessel. The upper head would also be disposed of intact or sectioned. If the upper head were disposed of intact, a cover plate would be installed over the bottom flange. Based on the neutron activation analysis, the reactor vessel and upper head would be packaged and shipped to the US Ecology disposal facility near Richland, Washington.

. The proposed change to the Decommissioning Plan adds the RVAIR option as a means of

removing and disposing of the reactor vessel and the reactor vessel internds. The RVAIR option

involves leaving the reactor internals in the reactor vessel, removing the reactor vessel with the i

internals and upper head intact, packaging the vessel for shipment, and disposing of the package at the US Ecology disposal facility near Richland, Washington.

i 8.8 TYPES OR AMOUNTS OF EFFLUENTS THAT MAY BE RELEASED OFFSITE Most of the activities associated with the RVAIR project will be performed within the Containment Building, as described in Section 1.2 of the RVAIR Plan. Radioactive gaseous effluents and

! radioactive liquid effluents resulting from decontamination and dismantlement activities will be

! monitored and processed per the DP (3.3.2.1 and 3.3.2.2, respectively) and release limits will be adhered to as stipulated in the ODCM.

8.9 RADIOLOGICAL OR HAZARDOUS MATERIAL EXPOSURE TO SITE WORKERS OR MEMBERS OF THE PUBLIC The RVAIR project will not result in increased exposure to radiological or hazardous material.

Removing 'and shipping the reactor vessel with the internals intact results in less occupational 4 exposure and less exposure to the general public than the removal of the reactor vessel and internals as currently described in the DP. The Radiation Protection Program is applied to activities performed onsite involving radioactive materials. Hazardous material handling is

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s REACTOR VESSEL ANDINTERNALS REMOVAL PLAN controlled by the Hazardous Material Control Program. Both programs are implemented through approved plant procedures.

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I REACTOR VESSEL AND INTERNALS REMOVAL PLAN 9

9. FIRE PROTECTION PLAN

' The Trojan Fire Protection Program is contained in Topical Report PGE-1012 and is administratively controlled by the plant fire protection procedures. The activities of the RVAIR project fall within the scope of these documents and are to be performed within their guidelines.

9.1 SAFE STORAGE OF IRRADIATED FUEL Them is no significant impn:t from a fire in Containment on the safe storage of irradiated fuel due to the low level of combustinl material that remains in the stmeture. The removal of the RCP lube oil and carbon filters has left electrical cable jacketing as the primary in-situ combustible loading. Section 5.3.5 of PGE-1012 demonstrates that cable jacketing burns inefficiently and does not pro note flame spread. This is enhanced by the de-energization of much of the cabling in the stmetum.

The most likely source of a fire in Containment will be from transient combustibles needed to support the RVAIR project and hot work activities such as welding and cutting. The Fire Protection Pmgram contains administrative controls that limit the amount of transients allowed in plant areas and requires permits for hot work activities. No additional controls have been

. identified that are required specifically for this project.

9.2 RELEASE OF RADIOACTIVE MATERIALS DURING A FIRE IN CONTAINMENT There are no large concentrations of highly contaminated, combustible materials in Containment.

The major contaminated materials consist of the piping, vessels, valves, pumps, and concrete or steel stmetures, which are primarily non-combustible. Small amounts of surface contamination exist on combustible cable mas, electrical panel components, and on painted surfaces throughout the building. A fire involving these components would be very small in nature, consuming any paint, lubricating oils, or plastics in the area. The major contribution to the fire loading in Containment will be from transients bmught in to support work activities. The amount of transient ,

combustible material concentrated in any one area is limited administratively by the Fire Protection procedw.

Section 3.4.4.5 of the Decommissioning Plan discusses a fire of this type and determined that a credible radioactive waste fire would not result in an airborne contamination release that would exceed allowed limits at the Exclusion Area Boundary. The study was based on a worst case scenario of a fire in a one-year ::upply of radioactive waste being stored in the Radioactive Waste ,

Storage Building. A fire in Containment would be significantly smaller in size due to the administrative liraits imposed on the area, therefore, a fire of this type in Containment would be bounded by the evaluation.

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• I REACTOR VESSEL ANDINTERNAL9 REMOVAL PLAN 9.3 EXCEPTIONS TO NFPA CODES AND STANDARDS NOTED IN THE FIRE PROTECTION PROGRAM i

l 9.3.1 Fire Protection Equipment j The primary Fire Protection equipment located in Containment consists of portable fire extinguishers located throughout the structure. Additional fire suppression capability would be provided by bringing fire hoses in through an air lock or the equipment hatch, as needed. During the RVAIR Project, it may be necessary to relocate a permanently mounted fire extinguisher to a new location to facilitate project activities. In this case, a portable stand for the extinguisher, or a relocated bracket, or the installation of additional temporary extinguishers may be used to maintain l

! the NFPA-10 (Portable Fire Extinguishers) required spacing for portable fire extinguishers. This will preclude requirit.g a new exception to NFPA Codes listed in PGE-1012.

j 9.3.2 Smoke Detection l

Limited smoke detection capability is provided in Containment by four portable, temporary smoke detectors that are currently located at the top of each steam generator cubical. They are mounted I on stands designed to be relocated if they interfere with ongoing work activities. Relocation of the detectors is covered under the Fire Protection procedures. The detectors were installed during the Large Component Removal project to provide minimal coverage during off- hours only. The subsequently installed Containment camera system has offset the need for these detectors by allowing the Control Room to periodically inspect the Containment for evidence of fire or smoke.

Because the detectors do not protect specific equipment or hazards, they are not required for the RVAIR project and would not create a new code deviation to NFPA-72, if impacted.

9.3.3 Fire Barriers The south wall of Containment, in which the roll-up door is located, is not a required 3-hour fire barrier, therefore no exception to NFPA is required for changes to the door or wall.

9.3.4 Administrative Requirements The administrative requirements for Fire Protection (such as for transient combustible control, flammable liquid control, and fire watches) are covered by Trojan Plant procedures. No changes to the Code requirements contained in the procedures have been identified for this activity.

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10. RADIOLOGICAL ENVIRONMENTAL AND EFFLUENT MONITORING  !

The RVAIR project does not change any plan to conduct a final radiation survey of the site to verify that contamination levels, concentrations, and direct radiation levels are such that the site can be released for unrestricted access. Removal of the reactor vessel will support this plan.  ;

As stated in Section 4 of this plan, the RVAIR project will not have a significant impact on the vegetation and wildlife in the area. No changes are required to the environmental and effluent monitoring programs. ,

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