ML20149H277

Summarizes 941021 Open Meeting W/Util & State of or Dept of Energy to Introduce Util Mgt to NRC Region IV Mgt & to Acquaint Region IV Mgt w/on-going Activities Re Util Proposed Large Component Removal Project.W/Related Info

ML20149H277
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	11/08/1994
From:	Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Quennoz S PORTLAND GENERAL ELECTRIC CO.
References
NUDOCS 9411220092
Download: ML20149H277 (54)

Text

{{#Wiki_filter:- _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. 54 UNITED STATES I $ 8 Rf Gg% 4 ?g NUCLEAR REGULATORY COMMISSION j LI j REGtON iv kh,7Jh 'gj 611 RYAN PLAZA DRIVE, SUITE 400 l AR LINGTON TEXA5 76011-8064 g s NOV - 8 1994 Portland General Electric Company ATTN: S. M. Quennoz Acting Vice President and Chief Nuclear Officer and Vice President Nuclear 121 S.W. Salmon Street, TB-17 Portland, Oregon 97204

SUBJECT:

OPEN MEETING OF OCTOBER 21, 1994 This letter documents the open meeting held at the NRC Region IV office on October 21, 1994, between representatives of Portland General Electric (PGE), NRC, and the State of Oregon's Department of Energy. The purpose of the i meeting was to introduce PGE management to NRC RIV management and to acquaint RIV management with the on-going activities related to PGE's proposed large l component removal project. PGE's handouts are enclosed with this letter. 1 During the meeting, discussions were held about the organizational structure ] of the Oregon Department of Energy, the Oregon Energy Facility Siting Committee, the NRC RIV Office, and the Trojan Nuclear Plant. The state's l l representative also discussed its historical role at the Trojan Nuclear Plant l and the current status of the rulemaking process affecting Trojan's proposed large component removal. Trojan's preliminary decommissioning schedule was j discussed as well as PGE's plans for future site activities. PGE l representatives stated that the utility company was evaluating the feasibility of constructing and operating a gas turbine on the site, bat that there were many questions which would have to be answered before a final determination could be made. PGE's representatives also presented a tentative schedule for large component removal. The schedule was tentative pending the outcome of the state's rulemaking proceedings and the court litigation which was on-going. No decisions were made during the meeting and no licensee commitments were made. Should you have any questions concerning this letter, we will be pleased to discuss them with you. Sincerely, /p-2./ / 3amuel J. Collins, Director l Division of Radiation Safety and Safeguards Decket: 50-344 License: NPF-1 I E nc l o s u re s.: 1. Attendance List 2. Licensee Presentation 9411220092 9411og DR ADOCK 05000344 4 01 PDR

b Portland General Electric Company cc: Trojan Nuclear Plant ATIN: M. Gatlin Security Manager / Supervisor Security Operations 71760 Columbia River Highway Rainier, Oregon 97048 Trojan Nuclear Plant ATTN: Tom Walt i General Manager, Technical Functions 71760 Columbia River Highway Rainier, Oregon 97048 Board of County Commissioners ATTN: Michael J. Sykes Board of County Commissioners Columbia County St. Helens, Oregon 97501 Oregon Department of Energy ATTN: David Stewart-Smith Salem Oregon 97310 Mr. Lloyd K. Marbet 19142 S.E. Bakers Ferry Road i Boring, Oregon 97009 Do It Yourself Committee ATTN: Jerry Wilson 570 N.E. 53rd Hillsboro, Oregon 97124 i Northwest Environment Advocates ATIN: Eugene Roselle 133 S.W. 2nd Avenue i Portland, Oregon 97204 l l

t I L l Portland General Electric Company bcc to DMB (IE01) bec w/ enclosures: LJCallan SWBrown, NMSS/DWM (T 7 F27) MTMasnik, NRR/0NDD-(llB20) SSBajwa, NRR/0NDD (11 B20) DWeiss, OC/LFDCB (4503) CLCain GMVasquez FAWenslawski MIS System RIV Files (2) HDChaney, WCF0 MLMcLean, FCDB RJEvans, FCDB LCCarson, FCDB DOCUMENT NAME: 0:\\F,CDB\\GMV\\TNP.LTR To twene a req 3 of thm J.icunwnt, exticate in the Nx 'C' - Copy without unulunent/encimure 'E' - Copy with attachmenucachwure 'N' - No Copy 0FFICE RIV:FCDB C:FCDB DD:DRSS D:DRSS NAME

• GMVasquez
• CLCain
• RAScarano
• SJCollins DATE

/ /94 / /94 / /94 / /94

• Previously concurred.

't Portland General Electric Company l -bcc t'o"DMB (IE01) t bcc w/ enclosures: i LJCallan SWBrown, NMSS/DWM (T 7 F27) MTMasnik, NRR/0NDD (11820) SSBajwa, NRR/0NDD (11 B20) l DWeiss, OC/LFDCB (4503) CLCain GMVasquez FAWenslawski. MIS System RIV Files (2) HDChaney, WCF0 MLMcLean, FCDB RJEvans, FCDB LCCarson, FCDB i ? i t f r i 4 I DOCUMENT NAME: 0:\\FCDB\\GMV\\TNP.LTR To nwne a mn of this d wument. uwin aic in tlw twx *C' - Con with.mt attactunent/cnclosure *E' - Copy a ath atwhmentlenelnaure *N' No con 0FFICE RIV:FCDB C:FCDB DD:DRSS D:DRSS l NAME

• GMVasquez
• CLCain
• RAScarano
• SJCollins DATE

/ /94 / /94 / /94 / /94

• Previously concurred.

n.

ENCLOSURE 1 ATTENDANCE LIST Attendance at the Portland General Electric Company Open Meeting on October 21, 1994, at the Region IV office. LICENSEE Tom Walt Harold Chernoff L% Joe Callan Sam Collins Ross Scarano Chuck Cain Michael Vasquez OTHERS David Stewart-Smith, Oregon Department of Energy ) _-._-_--__J

i i ENCLOSURE 2 i LICENSEE HANDOUTS I i i i ( u .[ I i k b i 4 e ? 3 + h i ) r I f I i f P h 4 =.- -~ - - - -

TROJAN ORGANIZATION AtilNG VICE PRESIDENT AND CHIEF NUCLEAR OFFICER' Trojan Nuclear Steve Quemor Operations Board GEkERAL MANAGER GENERgl MANAGER TROJAN GENERAL MANAGER GEhER4L MANAGER GENERAL MANAGER NUCLEAR OVERSIGHT PLANT ENGINEERING / TECHNICAL FUNCTIONS PLANT SUPPORT DECOMMISSIONING Dan Nordstrom Steve Quennoz Mike Lackey Tom Walt Paul Yundt Quality Assurance Plant Review Board Deconunissioning Licensing Asset Recovery Quality Control Maintenance Engineering Compliance Adninistrative Services Operations Corixment Removal Project Nuclear Fuel Cost Control Persomel/ Radiation Emergency Preparedness Nuclear Security Protection

• Individual filling these positions has the title of Trojan Site Executive arri General Manager, Trojan Plant pt.g/e o g U $ L

/7 0

Preliminary Decommissioning Schedule _ _;,g-n o -- ~ =- 1992 1933 1994 1995 1996 1997 1998 1999 2000 2015 2016 2017 2018 2019 Plant Closure State Approval Large p Component Removal t 4 Large Component (g Removal Project D-Plan Submittal X NRC/ State Approval j O D-Plan g Remove Reactor g internals ISFSi lmplementation k Dismantlement ( l ) Final Radiation W Survey Non-Contaminated a g V Building Demolition 1 l - -. - - -

Large Component Removal Project Schedule 7/94 8/94 9/94 10/94 11/94 12/94 1/95 2/95 3/95 4/95 5/95 6/95 7/95 8/95 9/95 10/95 11/95 12/95 State Rulemaking O ' E k NRC Approve Use of .g Trust Funds Prep ration NRC Review C of C A ~ Approval Plant Preparation (' Activities Heavy Lift Field Activities Component l Preparation j Barging of ( Components Negotiated Reduced ~ l Burial Rates j j l ~~ l 1 I I ___1

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(- MEMORANDUM 0F UNDERSTANDING BETWEEN THE STATE OF OREGON AND THE U. 5. NUCLEAR REGULATORY CCMMISSION 1 This Memorandum of Understanding between the State of Oregon (hereafter " State") and the U. 5. Nuclear Regulatory Commission (hereafter "NRC") i expresses the desire of the parties to cooperate in the reculation of nuclear activities; it sets forth mutually agreeable orinciples of cooperation between tne State and NRC in areas subject to the jurisdiction e of the State or tne NRC or both. This agreement is intended to provide tne basis of subsecuent detailed sub-agreements between the carties. Close cooperation between the sionatories will help assure that the goals and policies of State and Federal law will be carriec out efficiently and expeditiously without diminisnino ne responsibilities or autnorities of eitner party. With tne execution of this Memorandum, the State and NRC agree regula*1y to consult anc cocoerate in exploring and cevising appropriate procedures to minimize duplication of effort to the extent permitted by State and Federal law, to avoid delays in cecision making and to ensure the exchange of information nat is needed to make the most effective use of the resources of the State and NRC in order to accomolisn the curpose of botn carties. i I Principles of Cooperation 1. The State and NRC acree to exolore together tne development of detaileo sub-agreements in areas of mutual concern, includino siting of nuclear facilities;* water cuality; nuclear facility operation; confirmatory radiological anc environmental monitoring around nuclear facilities; decommissionino of nuclear facilities; emergency creoaredness clanninc; resoonse to radiological incidents; security Dianninc; personnel training and excnange; and radioactive material transoortation monitoring. For the purcose of this Memorandum of Understandino, the term nuclear f acilities is cefinec to incluce the following plants or f acilities within Oregon to the extent that these facilities are not covered oy the NRC-State agreement referenced in caragraon 4: a. Nuclear power, researcn, and test facilities, anc associated f acil ities ; b. Nuclear fuel reprocessino facilities; c. Uranium isotope enritnment facilities; d. Nuclear fuel f abrication plants; e. Nuclear waste treatment, storage, and disposal clants; Uranium milling clants anc mill-tailines; and c. Uranium nexaflucr1de conversion olants. 4333A

2. Sub-agreements under nis Memorancum may provide for activities to be performed by either party under mutually acceotable guidelines and criteria which assure that the neecs of both are met. For activities performed by one party at the request of the other Darty under specific sub-agreements to tnis Memorandum, eitht-party may explore means by wnich compensation can be made available to the other party or by which the costs may be shared by the parties. 3. Each party agrees to concurrently supply the other oarty copies of written corresoondence between it and One operator of a nuclear facility in Oregon. This agreement applies to proprietary information except as specifically proviced in the attached Sub-agreement 1. t Eacn party stands ready at the reouest of the other to provide reasonably available tecnnical information. 4 Nothing in this Memorandum is intendec to restrict or extend the constitutional or statutory authority of either NRC or the State or to affect or vary the terms of the present agreement (signed by Oregon Governor Mark 0. Hatfield anc AEC Chairman Glenn T. Seacorg in June 1965) between the State and NRC under Section 274b of ne Atomic Energy Act of 1954, as amenced. 5. The principal NRC contact under this Memorandum shall be the Director of the Office of State Programs. The orincipal State contact snall be the Director of the Oregon Department of Energy or his or her cesignee. Sub-agreements will name accropriate individuals, agencies ~i or offices as contacts. 6. This Memorandum snall take effect immediately upon signing by the Governor cf the State of Oregon ano tne Executive Director for Operations of the Nuclear Reoulatory Commission, and may be terminated upon 30 days written notice by either carty. i [ I ~

a i L FOR THE ST"TE OF OREGON ,/ I i I Q \\ ~ V1 to-Atiyen Govt.nor Dated at This// cay R /((8 r ? r I FOR THE UNITED STATES NUCLEAR REGULATORY COMMISSION / I < QJf

/

' f tee /. Goss1cx Executive Director for Ooerations Dated at W^ 't ???2'O"b Thisf*dayof(Jhe_ j /f/d [ ) b

SUB-AGREEMENT i SETWEEN THE OREGON DEPARTMENT OF ENERGY AND THE U. S. NUCLEAR REGULATORY COMMISSION PROTECTIVE AGREEMENT FOR EXCHANGE OF INFORMATIDN A. Scoce Thi: sub-agreement governs the conveyance between the United States Nuclear Reculatory Commission (NRC) anc the Oregon Department of Energy (ODOE) of documentary material, or copies thereof, "containing trace secrets or privileged or confidential commercial, financial, security information" ("oroorietary information") or h9spection manuals regarcing nuclear facilities (whether clanned, under construction or completed) witnin the State of Oregon. All sucn information shall be transmitted and received in conficence oy tne parties to

nis sub-agreement.

B. Provisions for :ne Conveyance of Information between the NRC anc the ODOE 1. Pursuant to 10 CFR 2.790 and 10 CFR 9.5(a) of tne NRC's regulations, the conveyed information is to be withheld from cublic cisclosure. ) 2. 10 CFR 2.790(b)(6) of the NRC's regulations permits the NRC to allow proorletary information to De subject to inspection under a protective agreement. Additionally, the NRC's disclosure in confidence of NRC inspection manuals by this agreement is expressly not to be construed as a ouclic disclosure of those cocuments. 3. CD0E agrees to accept and protect from public disclosure the materials orovicec by the NRC in confidence cursuant to one or more of the followinc sections of :ne Oregon revised statues (DRS): 192.500. (2)(b),192. 500 (2)(c),192.500 (2)(g), 469.080, 469.090, 469.550, and 469.990. 4 The only persons permitted access to information provided to CDOE oy NRC as a result of a conveyance under this agreement snall be the Director of the ODOE (" Director"), memoers of the Energy Facility Sitine Council (EFSC), tne Administrator of

ne Siting anc Regulation Program of the ODOE (" Siting ana Regulation Acministrator"), and the nuclear engineer staff remoers of tne Siting and Regulation Program (" nuclear engineers").

j l

5. Materials conveyed to tne ODOE under this agreement snail be stored in a bank safe deoosit box or a locked se:urity cabinet or safe to which access shall be provided no persons other than the Director, the Siting and Regulation Acministrator, and the nuclear engineers. 6. The Director, EFSC memoers, Siting and Regulation Administrator, and nuclear engineers snall make no copies of materials conveyed to the ODOE under this agreement and shall discuss the information conveyed to the 000E unaer this agreement with no persons other than themselves, the appropriate representatives of the comoanies wnicn supplieo the information to the NRC, and the aopropriate representatives of the NRC. 7. ODOE will maintain an inventory of all documents received under this agreement. The inventory and documents will be available for NRC review ucon request. 8. 000E agrees to review annually its inventory of ccnveyed l information and return tnose items no longer neeced. C. Classified Information In the event ODOE reouires access to classified information (e.g., restricted data or national security information) ODOE will work with NRC tc obtain the necessary authorization and to crovide the necessary facilities to review and store such information in accordance witn all Federal rules and regulations. 3. Authority Nothing in this sub-agreement is intended to restrict or extend tne constitutional or statutory autnority of either NRC or the State. E. Contac ts The princical NRC contact under tnis suo-agreement shall be the Chief, Safeguards Branen, Region V. The principal State contact i shall be the Administrator, Siting and Regulation of the Oregon Department of Energy. I F. Effective Date This suo-agreement snall take effect immediately upon signing by the Director of the 0 recon Department of Energy and the Executive Director for Ocerations of the Nuclear Regulatory Commissicn, and may be terminated ucon 30 days written notice oy eitner party.

i f FOR THE OREGON DEPARTMENT OF ENERGY WM ~ '/[9nn~ nk Dire or Dated at N '/ This / day A y-l FOR THE UNITED STATES' NUCLEAR REGULATORY COMMISSION I .) M ee V. Gossicx Executive Director for Operations Dated at W 4 9 7774LJ~f, ,,/ Thi s yanaday of a,,,,7 ' jygg r 3

SUB-AGREEMENT 2 BETWEEN THE OREGON DEPARTMENT OF ENERGY AND THE U. S. NUCLEAR REGULATORY COMMISSION RESIDENT INSPECTORS A. Scoce This sub-agreement covers the relationship between the United States Nuclear Regulatory Commission (NRC) and the Oregon Department of Energy concernino their respective resident inspector programs at the Trojan Nuclear Facility (Trojan) located 30 miles northwest of Portland, Oregon, and operated by Portland General Electric Company (PGE). During its 1979 Session, the Oregon Legislative Assembly enacted and the Governor signed Senate Bill 641 which reouires tne Oregon Department of Energy (0 DOE) to maintain an inspector at the site of a nuclear-fueled thermal power olant. Under the resident inspector program established by the Nuclear Regulatory Commission, the NRC's Office of Insoection and Enforcement has stationed its own resident inspector at Trojan. This agreement will specify the relationship between tne two programs. B. Traininc ) NRC will use its best efforts to make available space in its inspector training courses to accommodate any inspector or alternates hired by 000E to be stationed at Trojan. C. Insoection Manuals NRC will make inscection manuals available to ODOE. D. Authority The parties agree that the ODOE inspector will not have authority to direct PGE employees to take any action. Under Oregon law, this is witnin the exclusive State jurisdiction of the Director of the Oregon Decartment of Energy or in his absence, the Governor. The inspector will make nis recommendations to tne Director througn the Administrator, Siting and Regulation. The Director of the Oregon Department of Energy or in his absence, the Governor shall not require tne operators of Trojan to take action contrary to NRC requirements. If ODOE finds it necessary to direct the operators of Trojan to take action, ODOE shall obtain NRC's prior agreement that sucn action does not have an adverse effect on clant or public safety. Nothinc in this sub-aareement is intended to restrict or extend the constiiut cnal or staiutory autnority of eitner NRC or tne State. I

E. ODOE Insoector's Duties i The ODOE inspector's duties include the following: 1. Observing reactor plant maintenance, engineering, cuality assurance, security, emergency planning and operation to evaluate compliance with Federal and State safety standards. Specific aspects to be observed include the control of reactivity, radiological protection and control, water chemistry control, system repair and preventive maintenance, in-service inspections and periodic testing, and compliance with plant security programs. 2. Advising the State of Oregon about the significance of any incident at the olant, anc whether the corrective action taken is promot and complete, by reviewing engineering system design, sequence of events, ar.d trouble-shooting. This will include discussion of the inc1 cent with tne olant management and off-site engineering managers. 3. Reviewing changes in plant operating and maintenance procedures and system modifications for conformance with State and Federal requirements, compatibility with system design, and effect on safe plant operations. P 4 Researching plant conditions or cractices to succort ODOE j engineering evaluation of the safe coeration of the plant, including identification of as-built conditions, determination of historical cerformance of equipment, and review of operating practices. F. Workinc Relationsnios 1. The ODOE insoector will not attemot to cuolicate :ne regulatory activities of :ne NRC, but will ratner attemot to supplement the NRC regulatory activities. To the extent possible, tne ODOE and NRC insoectors will arrange their senedules and inspection activities so that their on-site activities complement each other, in urder to provide the widest oossible coverace of the plant and its operations. 2. The ODOE inspector will cocoerate with tne assigned NRC resident inspectors. The NRC inspector will reciprocate. 3. To the extent oossible, tne ODOE inspector may coserve NRC audits, reviews, insoections, investigations, drills and meetines at Trojan. In :ne same way, the NRC resicent inspector may ooserve 000E audits, reviews, insoections, investigations, crills and mee:1ncs at Trojan. The carties recognize that

nere will be occasions wnen, because of tne sensitive nature of ce-:ain mee:1ngs, it may oe necessary for the carties to conouct interviews privately and secaratelv.

4. The ODOE is invited to all NRC exit interviews. In the same )' way, to the extent possible the NRC inspector may attend ODOE exit interviews. PGE will advise the 000E and NRC inspectors of the time, date and location of all exit interviews. G. Contacts 4 The principal NRC contact under this sub-agreement shall be the i Director of NRC's Region V of' ice. The principal State contact shall be the Administrator of Siting and Regulation, Oregon Depart- .i ment of Energy. H. Effective Date This sub-agreement shall take effect immediately upon signing by the Director of the 0 recon Department of Energy and the Director of the Office of Inspection and Enforcement of the Nuclear Regulatory i Comission, and may be terminated upon 30 days written notice by either party. FOR THE OREGON DEPARTMENT OF ENERGY i / / / \\ ) 5Vi$ ?//W Lynn Fiank Director Dated at I# ihls day of g ? FOR THE UNITED STATES NUCLEAR REGULATORY COMMISSION / rictor 5feTio Director, Office of Inspection and Enforcement Dated at @ " d% 777e--!& This % day of , //fg a

i i Steam Generator & Pressurizer Removal Plan ,,,, m \\ r J / l t i i October 19,1994 l u -.m

Introduction . Scope of Project . Decommissioning Milestones . Reasons for Project . Description of Major Work . Schedule of Project and Major Milestones l . State Review Process j t . NRC Actions i l 1 t t $/' = i l

Scope of Project ) = Four Steam Generators (Model 51 A,331 tons) and Pressurizer (98 tons) - Remove = Remove the four Steam Generators and the Pressurizer via a new access cut in the south containment wall -Package = Prepare components as shipping containers 1 -Transport c = Ship the components via mobile transporter and barge -Dispose U.S. Ecology Site at Hanford, WA

1. r I

Preliminary Decommissioning Schedule h 2015 2016 2017 2018 2019 1992 1993 1994 1995 1996 1997 1998 1999 2000 k Plant Closure State Approval Large p Component Removal Large Component g Removal Project N D-Plan Submittai NRC/ State Approval E D-Plan Remove Reactor g Internals ISFSIimplementation k Dismantlement '(M Final Radiation Survey Non-Contaminated g Building Demolition ]. i i

Reasons for Project . Saves Estimated $4.5 Million over Doing Project During Planned Dismantlement Beginning in 1998 -Reduced burial cost negotiated with U.S. Ecology for 1994 & 1995 i - Availability of existing experienced personnel . Improves Decommissioning Project Integration -Justify maintaining additional Trojan expertise until dismantlement begins in 1998 -Provides decommissioning experience prior to beginning full-scale dismantlement ,$r +m

Description of Major Tasks l l l l l f/ ,$B

( \\ / O ~ \\ ,/' ~ ~ ~ - - ~ ^ ' ' ~ ~ - - - - - _,... L.) fonmw; 'f al / l f rse $f5 O n y L V ) EM 5> " y 5" 7 x a l e gl l y > oo Ri ~m/ %e$1 f n ,,a, gi 5I 1 5 es 4, Q y) m-( Ts 6' i m, L " ';O / E, d, R g J e Ap0 vJ7 3 -hr m, a b H' V 0 . L__ -t /y ' ' W % d! [,/ a NQ g ,/,- a1 s i* / -/. ./ E f// ,h i ~ t / x t o' p 2 Nll J$ k l ca i 3 / y S \\ (,,r ..} l l

U.S. Ecology Burial Facility Port of / Pasco Snake r River Port of Benton i Longview River Mile 342 f Kelso ^* * 'i I'* "j ' Columbia River I Flow Trojan River Mile 72.5 Vancouver McNary Dam s. River Mile 292 Portland 'N John Day Dam River Mile 217 s Willamette ~ \\x Bonneville Dam s R.iver River Mile 145 N The Dalles Dam River Mile 201 River Transport Route, Trojan To Port of Berr:on

~ l I-. [y niver i / / / Columbia River 24.5 Milesg 4% 17 Miles 200E fAREA / 26.5 Miles U.S. Ecology WPPSS 10.5 Miles E .N, ~~ Transport Route Port of Benton 3.5 Miles / i Hanford Nuclear / / / Reservation Boundary Private Property To Trojan f Over_anc Transaort Rou:e, Por: of Ben:on To U.S. Ecology

Large Component Removal Project Schedule 7/94 8/94 9/94 10/94 11/94 12/94 1/95 2/95 3/95 4/95 5/95 6/95 7/95 B/95 9/95 10/95l11/95 12/95 State Rulemaking NRC Approve Use of g Trust Funds rep rat on NRC Review C of C ( l Approval Plant Preparation ,o l l Activities i Heavy Lift Field l 'M Activities l I Comporient ( Preparation l Barging of g Components W Bu la Rates

State Review Process . Oregon Energy Facility Siting Council (EFSC) Adopted Rules on June 24 Providing Rulemaking Process to Review S/G Pressurizer Removal Project . Adopted Rule Established Criteria for Acceptable Project -Potential accident doses will not exceed EPA PAGs -Member of public will not receive projected doses exceeding 5 mrem due to normal effluents -Will not adversely affect potential for ) unrestricted use of the site after decommissioning -Will not adversely affect ability to comply with decommissioning plan standards in EFSC rules ~ 0 ,$r

State Review Process (continued) T = Rule Established Criteria for Acceptable Project (continued) -Will not increase estimated net present value of total decommissioning cost -Projected individual radiation doses to workers ALARA for proposed work . PGE Requested Rulemaking on July 7,1994 . Rulemaking Will involve EFSC Public Meeting and Special Advisory Group . EFSC Expected to Consider Rule in i November 1994 ,#r

NRC Actions . Conduct inspections . Assist State as Requested During their Rulemaking Process . Allow Use of Funds from Decommissioning Trusts for Project -PGE submittal made September 15,1994 . Approve Use of Components as Shipping Containers by -PGE submittal expected by December 1994 -NRC approval requested by June 1995 ,5r

DIVISICN 26 CONSTRUCTION AND OPERATION RULES FOR ENERGY FACILITIES e e Purpose 345-26-005 It is the purpose of these rules to assure that the construction, operation, and retirement of energy facilities is accomplished in a manner consistent with the protection of the public health, safety, and welfare and the protection of the environment. Stat. Auth: ORS CH. Hist.: NTEC 9, f. 2-13-75, ef. 3-11-75 Legislative Authority 345-26-010 These rules are promulgated pursuant to ORS 469. Stat. Auth: ORS CH. 183 & 469 Hist.: NTEC 9, f. 2-13-75, ef. 3-11-75; EFSC 1-1985, f. ef. 1-7-85 Scope and Construction 345-26-015 (1) These rules apply to all thermal power plants constructed, or under construction at the time of adoption of these rules, and operated or retired pursuant to a site certificatien agreement. (2) To the extent that any of these rules conflict or are inconsistent with administrative rules lawfully adopted by other state agencies, these rules shall be deemed controlling. (3) To the extent that any of these rules conflict or are inconsistent with a condition contained in a site certification i agreement (or amendment thereto), the latter shall be deemed controlling. j (4) Site certificate holders shall comply with all applicable lawful rules, regulations, and requirements of federal agencies. Stat. Auth: ORS CH. 183 & 469 Hist.: NTEC 9, f. 2-13-75, ef. 3-11-75; EFSC 1-1985, f. ef. 1-7-85 Definitions 345-26-020 (1) " Site" means all land upon which is located a thermal power plant and major associated facilities including, but not limited to, transmission line rights-of-way road and rail access, pumping plant, makeup or effluent water pipelines, dewatering flow easement, barge unloading facilities, cooling reservoirs, or discharge structures as defined in the site certificate. J (2) "Special nuclear material' means plutonium, uranium-233, or uranium enriched in the isotope 233 or in the isotope 235. Stat. Auth: ORS CH. (3) " Background" means the direct radiation (gamma) and concentrations of potential radionuclide contaminants in

t construction materials and environment in the vicinity of the plant not associated with the nuclear operation and retirement of the facility. Background shall be determined as follows: (a). Tor direct radiation, the results of any background measurements taken prior to operation of the facility shall be provided and 6 to 10 measurements shall be taken in areas t in the vicinity of the site with materials and/or geological formations representative of the site that have not been affected by the operation and retirement of the facility. Background shall be calculated at the average and at the 95% confidence level. (b) Environmental samples shall be taken for soil, sediment, water, and other materials present at the facility site that could have been affected by facility operations and retirement. Measurements for these samples shall be calculated at the average and 95% confidence levels, based on 6 to 10 measurements. Background environmental samples shall be taken at locations on site or in the immediate vicinity of the 'it vhich are unaffected by plant operations. BacwA ad shall be calculated at the average and 95% confidence vels, based on 6 to 10 measurements at each location. (c) For construction material such as concrete, asphalt, block, brick and other materials used to construct the buildings and systems at the site, representative samples of materials unaffected by site operations shall be i selected and surveyed. Six to ten samples of each material shall be taken to determine the level of naturally occurring and artificially induced concentrations of naturally occurring radioactivity present. Measurements shall include direct radiation (beta-gamma and alpha), wipes, and count room qualitatise and quantitative laboratory analyses. Concentrations of fission and activation products from historical fallout shall be characterized as well. l (d) All measurements shall be made using appropriate instruments, properly calibrated, and in sufficient number to determine compliance with requirements. Hist: NTEC 9, f. 2-13-75, ef. 3-11-75 Regulations Applicable During Both Construction and Operation THIS RULE IS DELETED IN ITS ENTIRETY 345-26-025 Stat. Auth: ORS Ch. Hist.: NTEC 9,

f. 2-13-75, ef. 3-11-75 Water Impoundments 345-26-030 NTEC 9, f.

2-13-75, ef. 3-11-75; -2

i Repealed by EFSC 1-1993,

f. & cert of 1-15-93)

Visitor Information 345-26-035- [ Renumbered to 345-27-020) Aesthetics 345-26-040 [ Renumbered to 345-27-020] Protection of Fish and Wildlife Resources 345-26-045 [ Renumbered to 345-22-060] Inspections 345-26-050 (1) General: (a) Each site certificate holder or operator of a nuclear installation shall afford to properly identified representatives of the Council opportunity to inspect all materials, activities, facilities, premises, and records at any time. (b) The site certificate holder's representative may acccmpany Cauncil inspectors during an inspection. (c) If, at the time of inspection, an individual has been authorized by the workers to represent them during Council inspection, the site certificate holder shall notify the inspectors of such authorization and shall give the workers' representative an opportunity to accompany the inspectors during the inspection of physical working conditions. (d) Each workers' representative shall be routinely engaged in work under control of the site certificate holder. (e) Different representatives of the site certificate holder and its designated workers may accompany the inspectors during various phases of an inspection if there is no resulting interference with the conduct of the inspection. However, only [ one workers' representative at a time =ay accompany the inspectors. (f) With the approval of the site certificate holder and the workers' representative, an individual who is not routinely engaged in activities under control of the certificate holder, for example, a consultant to the site certificate holder or to the workers' representative, shall be afforded the opportunity to accompany Council inspectors during the inspection of physical working conditions. (g) Council inspectors are authorized to refuse to permit accompaniment by an individual who deliberately interferes with a fair and orderly inspection. (h) Representatives accompanying Council inspectors in areas i containing proprietary information shall be individuals previously authorized by the site certificate holder to enter that area. f -3 l ,r a

1 (i) Upon completion of each inspection the inspector shall have a conference with the person responsible for the project at the site to discuss all pertinent findings. The inspector shall issue a written report of the inspection and this conference. Inspection reports shall be kept on file at the ODOE office. (j) If any violation of state law, Council rules, or site certificate conditions or warranties is discovered, the Council Chairman shall be notified immediately. All pertinent findings shall be reported to the full Council at its next scheduled meeting. (2) Consultation with Workers during Inspection: (a) Council inspectors may consult privately with workers concerning matters related to applicable provisions of state law, Council regulations, and site certificate conditions to the extent the inspectors deem necessary for the conduct of an effective and thorough inspection. (b) During the course of an inspection, any worker may bring privately to the attention of the inspectors, either orally or in writing, any past or present condition which he has reason to believe may have contributed to or caused, or is likely to cause, any violation of state law, regulations of the Council, site certificate condition or warranties, or any unnecessary exposure of an individual to radiation from radioactive material under l control of the site certificate holder. Such notice concerning i state law or rules not administered by the Council shall be forwarded by the inspectors to the appropriate state agency. (3) Requests by Workers for Inspections: (a) Any workers or representative of workers may, under conditions expressed below, request an inspection by giving notice of the concern to the administrating state agency, or to Council inspectors during inspections, who shall forward such l notice to the appropriate state agency. Such a request may be made when the requesting party believes: (A) That a violation of state law, regulations of the i Council, or site certificate conditions or warranties exists or has occurred; or (B) A situation exists that may lead to such a violation or to unnecessary exposure of an individual to radiation from radioactive naterial under control of the site certificate holder. Concern with regulations of the Council or site certificate conditions or warranties shall be made to the Council's staff, or to the Council inspectors. Such notice shall be in writing, shall# set forth the specific grounds for the notice, and shall be signed by the worker or representative of workers. A copy shall be provided to the site certificate holder by the Council's staff or the inspector no later than at the ti=e of inspection. Upon the request of the person giving such notice, his name and the name of individuals referred to therein shall not be disclosed in any nanner, except where required by law. ] _4 l 1

(b) If the Council's staff concludes there are reasonable grounds to believe that the alleged violation exists or has occurred, it shall cause an inspection to be made as soon as practicable. Inspections conducted pursuant to this section need not be limited to matters referred to in the complaint. (c) No site certificnte holder shall discharge or in any manner discriminate agair.st any worker because such worker has filed any complaint or '.nstituted or caused to be instituted any proceeding under these, regulations or has testified or is about to testify in any sudi proceeding or because of the exercise by i such worker an helialf of himself or others of any option afforded by these rules. (d) If the Council's staff determines that an inspection is not warranted, it shall give written notice to the complainant. The complainant may submit a written request for review to the Council if their inspection request to the administering state agency or the Council staff has been denied. The Council shall provide the site certificate holder with a copy of such statemenr. by certified mail, excluding the name of the complainant, if so requested. The site certificate holder may submit written statement of its position with the Council, which shall provide a copy to the complainant by certified mail. Upon their own motion or the request of either the complainant or the site certificate holder, the Council or its designee may hold an informal conference to discuss the issue. After considering all written and oral views presented, the Council shall affirm, modify, or reverse the previous determination and furnish the complainant and the site certificate holder a written notification of its decision and the reasons therefor. Stat. Auth: ORS Ch. Hist.: NTEC 9, f. 2-13-75, ef. 3-11-75 Environmental and Effluent Monitoring 345-26-060 (1) Where warranted the site certificate holder for any non-nuclear facility shall initiate and maintain environmental and effluent monitoring of the site, thermal power plant, and associated facilities. Specific plans for the performance, modification, and reporting of these monitoring programs shall be reviewed and concurred in by the appropriate state agencies. All program plans and reports as listed below shall be provided to the Council. The Council, after consultation with the appropriate state agency, may approve or modify those plans. In instances:where state agencies are performing contracted monitoring services for the site certificate holder, the Council may arrange for independent review of the plan. (2) The site certificate holder shall provide adequate quality assurance measures for the environmental.and effluent monitoring program. These quality assurance measures shall provide adequate confidence that a structure, system or component will perform satisfactorily in service and shall be j _ 5 _ i

incorporated in plant policies, procedures, or instructions. The site cartificate holder shall regularly review the status and adequacy of these quality assurance measures. The measures shall be submitted to the Oregon Department of Energy for concurrence at the earliest ~ practical time consistent with the schedules of the monitoring programs. (3) The results of the monitoring programs shall be used to determine what areas require further study, corrective action, or special reports by the site certificate holder and shall describe these actions. Unless otherwise specified by the Council the monitoring programs will include the following: (a) Structural Performance of Hydraulic Structures. Structural performance monitoring of major hydraulic structures and water-budget accounting shall be perfor=ed. Detailed plans for this monitoring shall be submitted to the Water Resources Department for concurrence and shall include details of location and design of equipment, including instrumentation of major embankments for pore pressure, seepage settlement, and deflection. (b) Fish Screening at Intake Structure. Fish screening at the pumping plant intake structure shall be =enitored to determine effects on the fisheries resource. Detailed plans for i this monitoring shall be submitted to the Department of Fish and Wildlife for concurrence, and shall include frequency of sampling and reporting levels. (c) Receiving Water Quality Monitoring. A program shall be instituted by the site certificate holder to provide baseline information, and to identi'fy and monitor impact of plant construction, operation and retirement on receiving water bodies of any discharges from the thermal power plant and the site. This program shall be submitted to the Department of Environmental Quality for concurrence. (d) Liquid Effluent Monitorine. A program shall be instituted by the site certificate holder to monitor for the presence of pollutants.in the liquid effluents from the thermal power plant and related facilities. The program shall be submitted to the Department of Environmental Quality for concurrence. (e) Groundwater Monitoring. A groundwater monitoring program shall be established in selected locations near and on the site to determine whether groundwater quality is being adversely affected by the thermal power plant or associated facilities. The detailed plan for this monitoring shall be submitted to the Water Resources Department ~and the Department of Environmental Quality l for concurrence. (f) Aquatic and Terrestrial Ecology Monitoring. A program shall be instituted by the site certificate holder to provide baseline information and identify any impact of plant construction or opera-ion on aquatic and terrestrial ecology. This program shall be submitted to the Department of Fish and Wildlife and the Department of Environmental Quality for concurrence. The following will be included as necessary: -s-

(A) Determination of the extent and manner of fish and wildlife use of the site before plant construction. (B) The actual impact of plant construction and operation on fish and wildlife. (C) Studie's and =onitoring as necessary of vegetation and crops commonly grown in the area for the purpose of determining the extent of vegetation damage, if any, froa plant operation. (D) Except at nuclear power plants, the program will evaluate or monitor for any chemical build-up in soils or vegetation from operation of the facility. l (E) Results from the above will be provided to the Council pursuant to CAR 345-26-075. (g) Air Quality Monitoring for Coal-Fired Plant. An air quality monitoring program for coal-fired plants shall be established. This program shall require the concurrence of the Department of Environmental. Quality and shall include: (A) Ambient air quality monitoring for =easurement of air contaminants as may be required by the Department of Environmental Quality. The monitors will be located to include to the extent possible the area of maximum concentration realistically expected at a frequency of occurrence specified by the Department of Environmental Quality. This monitoring will be conducted to determine the air quality degradation caused by plant operations. (B) A=bient air quality studies for the site shall include efforts to evaluate possible plant impacts on regional visibility and acid rain for facilities obtaining a site 1 certificate after January 1, 1985. (C) A diffusion model analysis designed specifically for stack emissions from the plant shall be developed on a schedule approved by the Oregen Department of Energy. The results from modeling plant emissions will be compared to data collected from ambient air quality monitors. The adequacy of the model will require approval of the Department of Environmental Quality. Once accepted, it shall be the basis for any change in meceorological or ambient air quality =enitoring requirements. (D) Air quality data including emissions measurements, ambient air data, and related environmental monitoring information reports submitted to the Department of Environmental Quality on the appropriate schedule. (E) Meteorological Monitoring. Meteorological monitoring data shall be obtained from the site, or other representative location beginning at least one year prior to application for a site certificate. This program shall provide meteorological information sufficient to support efforts to determine the effect of the plant and associated facilities on air quality and provide information on site conditions and data for dispersion modeling. This program shall be submitted to the Depart =ent of Environmental Quality for concurrence. (h) Emissions and Fuel Monitoring for Coal-Fired Plant: (A) Sampling and testing of emissions and fuel shall be in i ~- I

accordance with " EPA Standards of Performance for New Fossil-Fuel Fired Steam Generators" and amendments applicable to the facility. Further, such facilities shall comply with Department of Environ = ental Quality requirements and any additional require =ents of the Council in effect at the time a site certificate is granted to an applicant. The type and location of monitoring requirements and facilities shall require concurrence by the Department of Environmental Quality. (B) Provisions shall be included in design for continuous read-out of selected emission monitoring equipment as approved by the Department of Environmental Quality. (i) Radioactivity Impacts From Thermal Plants Other Than Nuclear Plants. A program to evaluate the radiological impacts upon the environment from fly ash or other effluents may be required by the Council. This program shall be concurred in by the Department of Energy and the Oregon State Health Division. [ Publications: The publication (s) referred to or incorporated by reference in this rule are available from the office of the Energy Facility Siting Council.] Stat. Auth: ORS Ch. 183 & 469 Hist.: NTEC 9, f. 2-13-75, ef. 3-11-75; EFSC 1-1985, f. & ef. 1-7-85 Reliability of Pollution Control Equipment 345-26-070 The site certificate holder shall provide adequate quality assurance =easures to ensure the high reliability of pollution control equipment. These quality assurance measures shall provide adequate confidence that a structure, system or component will perform satisfactorily in service and shall be incorporated in plant policies, procedures, or instructions. This program will initially be approved by the Department of Energy. The site certificate holder shall regularly review the status and adequacy of these quality assurance measures. Stat. Auth: ORS Ch. 183 & 469 Hist.: NTEC 9, f. 2-13-75, ef. 3-11-75; EFSC 1-1985, f. ef. 1-7-85 Environmental Report 345-26-075 (1) For non-nuclear energy facilities, annual environmental and effluent release monitoring reports prepared to fulfill require =ents of OAR 345-26-060 shall be submitted to the Council within 120 days of the end of the calendar year, or an alternate schedule with prior approval of the Department of Energy. Alternate schedules may be approved considering work loads of the site certificate holder and Department of Energy and/or schedules for submittal of similar reports to other state or federal agencies. Each report will thenceforth be annually reportable en the approved date. The report shall include, when appropriana, a discussion of any changes in the techniques being used or planned to control pollutant discharges or adverse -8

environmental impacts during the reporting period. Where appropriate other techniques that might further abate pollutant discharges will be discussed. The corresponding reduction in emissions or impacts and any discharges of pollutants for each discussed technique shall be predicted. (2) Where the holder of a site certificate beco=es aware of i a significant environmental change or impact attributable to the

facility, an interim written report discussing this issue will be submitted to the Department of Energy as soon as reasonably possible.

Stat. Auth: ORS Ch. 183 & 469 Hist.: NTEC 9, f. 2-13-75, ef. 3-11-75; EFSC 4-1980, f. ef. 4-25-80; EFSC 1-1985, f. & ef. 1-7-85 Plant Status 345-26-080 For non-nuclear facilities, the site certificate holder shall submit to the Council, as the Council deems i a i necessary to demonstrate compliance with the site certificate, i summary report on site conditions and the status of construction for units under construction or for completed plants, a su= mary reporting of the operation of the plant and associated facilities. The appropriate report shall summarize current status and changes including the social and economic impact of the facility, and indicate the significance of the changes. If another report or series of reports is required by other state or federal agencies containing similar information on a similar or more frequently submitted basis, the forwarding of such reports to the Council may replace the requirement for an annual report with the prior approval of the Department of Energy. l Stat. Auth: ORS Ch. 183 & 469 Hist.: NTEC 9, f. 2-13-75, ef. 3-11-75; EFSC 1-1985, f. ef. 1-7-85 Social and Economic Impact Report 345-26-085 The site certificate holder shall prepare and submit to the Council prior to start of plant construction a report describing plans to reduce adverse or to enhance beneficial social and economic impacts of plant construction on the surrounding area. This report should include any reco== ended actions to be taken by nearby cities, counties, and state agencies. This report shall include, but not be limited to, possible early flow of tax dollars to affected areas, provision of adequate housing,'necessary community services such as education, sewage treatment, water, and medical facilities. Stat. Auth: ORS Ch. Hist.: NTEC 9, f. 2-13-75, ef. 3-11-75 i Reliability of Power Production 345-26-090 (1) For electric generation plants, the site certificate holder shall provide adequate quality assurance i

measures for syste=s or components essential to reliability of power production by the facility. These quality assurance measures shall provide adequate confidence that these syste=s or components will ;r-form satisfactorily in service and shall be incorporated i). plant policies, procedures or instructions. These measures w ll be initially approved by the Oregon Department of Ene.'gy. The site certificate holder shall regularly review the status and adequacy of these quality assurance measures. (2) An annual report of equipment and plant breakdowns shall be submitted to the Council along with plans to minimize such breakdowns. This report shall also include the plant availability and capacity factors for the reporting year unless this information is reported elsewhere. Stat. Auth: ORS Ch. 183 & 469 Hist.: NTEC 9, f. 2-13-75, ef. 3-11-75; EFSC 1-1985, f. ef. 1-7-85 Financial Report 345-26-095 For non-nuclear energy facilities, the site certificate holder and any co-owners or successors in ownership shall provide the Council as necessary with an annual financial j report which demonstrates the financial qualifications to i construct and operate the plant. The report shall include a discussion of any changes in fuel contracts and any changes in the financial and physical plans for retirement of the plant, or any changes in the status of these contracts and retirement plans. Stat. Auth: ORS Ch. 183 & 469 Hist.: NTEC 9, f. 2-13-75, ef. 3-11-75; EFSC 1-1985, f. ef. 1-7-85 Planning and Funding for Decommissioning of Nuclear Power Plants THIS RULE DELETED IN ITS ENTIRETY 345-26-096 Stat. Auth: ORS Ch. 469 Hist.: EFSC 1-1986, f. & ef. 1-22-86 Schedule Modification 345-26-100 The Council shall be notified at its next regularly scheduled meeting following any changes in major milestones for construction, decommissioning, or cperation schedules. Major miiestones shall be as identified by the site certificate holder in its construction or decommissioning plan. Stat. Auth: ORS Ch. Hist.: NTEC 9, f. 2-13-75, ef. 3-11-75 Correspondence With Cther State or Federal Agencies 345-26-105 Copies shall be exchanged between the site certificate holder and the Cregon Department of Energy of a 1.

i correspondence related to thermal power plant construction or operation which are submitted to a state or federal agency, except for material withheld from public disclosure under state or federal law or under Council rules. Abstracts of reports may j be submitted ir place of full reports; however, full copies of i abstracted reports must be provided at the request of the Oregon ) Department of Energy. Stat. Auth: ORS Ch. 183 & 469 Hist.: NTEC 9, f. 2-13-75, ef. 3-11-75; EFSC 1-1985, f. ef. 1-7-85 Security Plans for Nuclear Power Plants and Nuclear Materials THIS RULE IS DELETED IN ITS ENTIRETY 345-26-110 Stat. Auth: ORS Ch. Hist.: NTEC 9, f. 2-13-75, ef. 3-11-75 Intake and Discharge Structures 345-26-115 Stat. Auth: ORS Ch. Hist.: NTEC 9, f. 2-13-75, ef. 3-11-75 Repealed by EFSC 1-15-93 Regulations Applicable During Construction 345-26-120 In addition to those rules specified in rule 345-26-025, rules 345-26-125 through 345-26-135 apply to a site certificate holder during construction of a thermal power plant and associated facilities. Stat. Auth: ORS Ch. 183 & 469 Hist.: NTEC 9, f. 2-13-75, ef. 3-11-75,- EFSC 1-1985, f. ef. 1-7-85 Construction Report 345-26-125 During construction, the site certificate holder shall submit copies of the monthly Construction Progress Reports to the Council. Stat. Auth: ORS Ch. Hist.: NTEC 9, f. 2-13-75, ef. 3-11-75 Geology 345-26-130 [ Renumbered to 345-27-010] Historic, Archaeologic, and Paleontologic Sites 345-26-135 [ Renumbered to 345-22-090] Regulations Applicable During Operation 345-26-140 In addition to those rules specified in rule 345-26-025, rules 345-26-145 through 345-26-195 apply to a site certificate holder during operation of a thermal power plant and associated facilities. 1

Stat. Auth: ORS Ch. Hist.: NTEC 9,

f. 2-13-75, ef. 3-11-75 Fire Protection for Nuclear Installations THIS RULE IS DELETED IN ITS CfTIRETY 345-26-141 Stat. Auth: ORS Ch. 469 Hist.: EFSC 3-1980, f.

& ef. 3-4-80 Site Uses THIS RULE IS DELETED IN ITS ENTIRETY Stat. Auth: ORS Ch. 469 Hist.: NTEC 9, f. 2-13-75, ef. 3-11-75; EFSC 4-1983, f. ef. 12-20-83 Power Production THIS RULE IS DELETED IN ITS ENTIRETY Stat. Auth: ORS Ch. Hist.: NTEC 9,

f. 2-13-75, ef. 3-11-75 Pollution Discharges 345-26-155

[NTEC 9, f. 2-13-75, ef. 3-11-75 Repealed by EFSC,

f. & cert. ef. 1-15-93)

Violations 345-26-160 In the event that air or water pollution control equipment or a related facility malfunctions or breaks down or other factors result in emissions or discharges in violation of j applicable standards, the site certificate holder shall take the fc11owing action: (1) In the event of a violation of an emission standard or j discharge limit administered _by an agency other than the Council, the site certificate holder shall provide the Oregon Department of Energy all notifications required by that agency within one work day of notification of tte responsible agency. (2) In the case of emission or discharge standards imposed by the Council over and above those of other state agencies, the site certificate holder shall: (a) Notify the Oregon Department of Energy, by telephone or in person, of such failure or breakdown within one hour of the occurrence, or as soon as is reasonably possible, giving all pertinent facts including the estimated duration of the breakdown. (b) With all practicable speed, initiate and complete appropriate action to correct the conditions, and to reduce the frequency of such occurrences. (c) Cease or discontinue operations of the thermal power plant no later than 48 hours after the beginning of the I -

violation of the emission or discharge standards if the violation is not corrected by that time. (d) Submit to the Oregon Department of Energy an initial written report of a failure or breakdown within 10 days. When the condition has been corrected, submit a final written report to the Oregon Department of Energy describing the causes and the actions taken to prevent similar upsets or breakdown conditions. t The initial and final reports may be combined if it can be submitted within ten days of the failure and breakdown. Stat. Auth: ORS Ch. 183 & 469 Hist.: NTEC 9, f. 2-13-75, ef. 3-11-75; EFSC 1-1985, f. ef. 1-7-85 Performance Tests of Equipment and Procedures Controlling i Pollution Emissions and Discharges 345-26-165 (1) Within 60 days after achieving the maximum i production rate at which the thermal power plan will be operated, i or no later than 180 days after initial start-up of the plant and l at such other times as may be required by the Council, the certificate holder shall concoct performance test (s) of emission and discharge control equipment and furnish the Oregon Department i of Energy and the Department of Environmental Quality a written report of the results of such performance test (s). i (2) Performance tests shall be conducted and results reported in accordance with the test =ethod approved by the Oregon Department of Energy. l (3) The site certificate holder of an affected facility shall provide the Oregon Department of Energy ten days prior notice of the performance test to afford the Oregon Department of l Energy the opportunity to have an observer present. (4) The certificate holder shall provide all necessary l facilities for the performance test. Stat. Auth: ORS Ch. 183 & 469 Hist.: NTEC 9, f. 2-13-75, ef. 3-11-75; EFSC 1-1985, f. ef. 1-7-85 Notification of Incidents 345-26-170 (1) The Council shall be notified within 24 hours of any occurrence involving the thermal power plant if: (a) There is an attempt by anyone to interfere with the safe or reliable operation of the thermal power plant. (b) A natural event such as an earthquake, flood, tsunami or tornado, or a man-caused event such as a fire or explosion affects or threatens to affect the safe or reliable operation of the thermal power plEnt. (c) There is damage to property in excess of $100,000. (d) There is any fatal injury at the thermal power plant site to a certificate holder employee or a member of the public. (e) There is an unplanned shutdown of the thermal power plant, i expected to last greater than one week, is necessitated: (2) Nuclear T wer Plants. = ~- . v

4 In the event of incidents or accidents requiring notification of the Nuclear Regulatory Commission by telephone, (a) the Oregon Department of Energy shall also be provided such notification on the same time schedule.The Oregon Department of Energ of all incidents in accordance with the Trojan Emergency Response (b) Security Plan, and other agreements as established. Plan, Stat. Auth: ORS Ch. 183 & 469 Hist.: NTEC 9, f. 2-13-75, ef. 3-11-75; EFSC 1-1985, f. ef. 1-7-85 Radioactive Pollutants From Nuclear Power Plantsand 345-26-165 do not 345-26-175 Rules 345-26-160(2)(c) i apply to radioactive pollutants. Stat. Auth: ORS Ch. Hist.: NTEC 9, f. 2-13-75, ef. 3-11-75 Coal and Ash Handling for Fossil-Fueled Thermal Power Plants 345-26-180 [ Renumbered to 345-27-020) New Fuel for Nuclear Power Plants 345-26-18f The use of new fuel contain specific approval of the Council and in prohibited without it establishes. accordance with procedures that Stat. Autn: ORS Ch. Hist.: NTEC 9,

f. 2-13-75, ef. 3-11-75 i

Emergency Planning for Nuclear Power Plants f THIS RULE IS DELETED IN ITS ENTIRETY 'i 345-26-190 Stat. Auth: ORS Ch. 183 & 469 Hist.: NTEC 9,

f. 2-13-75, ef. 3-11-75; EFSC 4-1978, f.

i ef. 4-3-78; EFSC 1-1985,

f. & ef. 1-7-85 Radioactive Material Inventory and Transportation for Nuclear Power Plants 345-26-195 NTEC 9, f. 2-13-75, ef. 3-11-75;

& ef. 1-7-85 Repealed by EFSC 1-1985,f. l Exemption The Council may, either upon written application or on its own motion,,saive or delay compliance with any of these 345-26-200 i ~ if after a public hearing, rules as applied to a specific site, such action will not result in injury to the l it concludes that public health, safety, or welfare. Stat. Auth: ORS Ch. Hist.: NTEC 9,

f. 2-13-75, ef. 3-11-75 l

1 i r 14 - I i c

e Regulations Applicable to Nuclear Installations 345-26-300 NEW RULE (1) The requirements of OAR 345-26-300 through 400 apply exclusively to Nuclear Installations in Oregon as defined in ORS 469.300. (2) OAR 345-26-300 through 400 do not apply to faciltiies under the jurisdiction of OAR 345 Division 30. i Nuclear Fuel Prohibited in Trojan Reactor Vessel 345-26-310 NEW RULE Placement of nuclear fuel in the Trojan reactor vessel is prohibited. I l Environmental and Effluent Monitoring for Nuclear Installations 345-26-320 NEW RULE All environmental and effluent programs established pursuant to oregon Department of Environmental Quality Rules or in consultation with the Department of Fish and Wildlife shall be provided to the Oregon Department of Energy. The Oregon Department of Energy, with concurrence of the appropriate state agency, may approve or modify these programs. Any modifications to programs delegated to the State by the Federal government may not be in conflict with ~ Federal requirements. Radiological Environmental and Effluent Monitoring 345-26-330 NEW RULE (1) A radiological environmental and effluent monitoring program shall be established by the site certificate holder and submitted to the Department for approval within 60 days of the effective date of this rule. (2) The site certificate holder shall describe'the quality assurance measures applicable to the radioactive environmental and effluent monitoring programs in the program plan. (3) Changes to the radiological environmental monitoring program that involve one of the following require Department approval prior to implementation: (a) A reduction in the number and type of environmental samples analyzed; or, (b) A change in the verification of the accuracy of the effluent monitoring program and modeling of exposure cathways.

1

4. (4) Modifications to the radiological environmental =cnitoring program that do not involve a change meeting the criteria listed in (3) above do not require prior Department approval. These changes shall be submitted to the Departmenwithin 60 days of implementation of the change. t The Council shall be notified of any such changes at its next scheduled meeting. Security Plans for Nuclear Installations 3 345-26-340 NEW RULE (1) The operator of a nuclear installation shall establish and maintain a security plan with capabilities for protection of special nuclear material. (2) Upon assurance satisfactory to the Council and the site certificate holder that confidentiality can be =aintained, a security plan for nuclear installations shall be made available to authorized Council representatives in accordance with U.S. Nuclear Regulatory Commission regulation 10CFR 73. 21(c) (iii) within 60 days of the effective date of this rule for inspection and approval. Approval of the plan by both the Council and the Director, Oregon Department of Energy must be obtained. (3) Proposed modifications to the security plan that involve a reduction in the ability to detect or prevent unauthorized entry, or a reduction in the ability to detect or prevent the introduction of unauthorized material into the Protected Area or otherwise lessen the effectiveness of the physical security plan require written Department concurrence prior to implementation. (4) Modifications to the plan which do not lessen the effectiveness of the plan may be implemented without prior Department concurrence. Copies of the revised plan shall be submitted to the Department within 60 days of the implementation date. The Council shall be informed of these changes at its next scheduled meeting. Emergency Planning for Nuclear Installations 345-26-350 NEW RULE (1) The operator of a nuclear installation shall prepare, comply with, and maintain in readiness an emergency response plan. The plan must ensure adequate measures will be taken in the event of a radiological emergency. The Emergency Plan shall be submitted to the Council within 60 days of the effective date of this rule for its approval. _

Proposed modifications to the e=ergency plan that (2) one of the following require EFSC approval prior to involve implementation. (a) ~A change (other than editorial) in the Emergency Action Levels; or, A decrease in the planned staff augmentation (b) capabilities; or, A reduction in the plan requirements for (c) notification of off-site agencies. Modifications to the plan which do not meet one of the (3) above may be implemented without criteria listed in (2) Copies of the revised plan shall be prior EFSC approval. submitted to the Department within 30 days of the The Council shall be not_fied at its implementation date. scheduled meeting of such changes. next I Fire Protection 345-26-360 NEW RULE Any holder of a site certificate for a nuclear installation shall implement within 60 days of the effective (1) date of this rule a fire protection program consistent with applicable codes and, standards of the National Fire Exceptions to the codes and Protection Association. standards shall be documented and justified in the fire protection plan. f Proposed plan revisions involving changes to the l (2) exceptions to the codes and standards may not be made l without prior Department concurrence. (3) Plan revisions which do not involve changes to the exceptions to the codes and standards may be implemented Such plan revisions without prior Department concurrence. shall be transmitted to the Department within 60 days of The Council shall be notified of any such implementation. changes at its next regularly scheduled meeting. Standards for Council Approval of the Decommissioning Plan 345-26-370 NEW RULE The operator of a nuclear installation shall submit 15 (1) copies of a plan for decommissioning a facility to the for Council approval. The plan shall be Department submitted to the EFSC on a schedule consistent with that When Nuclear Regulatory Commission. required by the U.S. receives a decommissioning plan, the the department department shall:, /

i 1 1 issue notice to the Council's mailing list that (a) the decommissioning plan has been submitted. The notice shall include: (i) the time and place of at least one " informational hearing, (ii) the locations where copies of the proposed plan may be reviewed by the public, and (iii) a contact name for further information. (b) perform a technical review, and produce a staff report containing the department's technical conclusions, recommendations on specific issues raised in the proposed plan, and staff's recommended conclusions for the Council, i (c) to the extent practicable, coordinate its technical review with that of the U.S. Nuclear Regulatory Commission, (d) issue notice of availability of the department's The notice staff report to the Council mailing list. shall include:summary of the department's (i) a recommendations, (ii) time and place of a hearing on the staff

report, (iii) places where the department's staff report may be reviewed by the public, (iv) a contact for additional information and copies of the staff report, (v) the date by which a petition for contested case review of the department's recommendation must be received by the department, and (vi) a statement that, except as provided in OAR 345-15-083(2), failure to raise an issue in a petition for contested case on the department's recommendation constitutes a waiver of that issue.

(vii) A statement that a petition for contested case hearing will be considered by the Council according to the criteria in parts (e) (i), (e) (ii) and ( e) (iii) of this rule. (e) within 30 days of the notice required in (d) of this rule, any person may petition for contested case review of the department's recommendations. The petitioner must raise issues with sufficient afford the Council or hearings officer specificity to and the parties an adequate opportunity to respond to each issue. The Council may reject the petition, or contested case on all or some 94 the issues grant the raised in petition. The contested case, if granted, shall be conducted in accordance with applicable requirements of division 15 of Council rules. In ! i

1 considering the petition for a contested case hearing, the Council shall consider whether there exists (i) A significant safety issue that requires the procedural controls of a contested case to determine the'ippropriate action, or A question as to whether an EFSC standard was (ii) which requires a contested case to determine being met, the answer, or (iii) whether there was an opportunity via another proceeding for a contested case to be held. The Council shall review the proposed decommissioning (2) plan to verify that the proposed activities will not the health and safety of the public or the adversely affect The Council will ensure the following when environment. evaluating acceptability of a proposed decommissioning plan: The plan contains criteria for the free release of (a) materials and.the area as specified in Table 1 below: TABLE 1 ACCEPTABLE SURFACE CONTAMINATION LEVELS AVERAGE MAXIMUM REMOVABLE NUCLIDE Natural Uranium, U-235, U-238, 5000 15000 1000 dpm and associated decay products dpm dpm alpha alpha alpha Transuranics, Ra-226, Ra-228, 100 dpm 300 dpm 20 dpm Th-230, Th-228, Pa-231, Ac-227, I-125, I-129 Natural Thorium, Th-232, Sr-90, 1000 3000 200 dpm Ra-223, Ra-224, U-232, I-126, I-dpm dpm 131, I-133 5000 15000 1000 dpm Beta-gamma' emitters with decay modes other than alpha emission dpm dpm beta / or spontaneous fission except beta / beta / gamma Sr-90 and others noted above gamma gamma NOTES: Where surface contamination by both alpha and beta-gamma emitting a. nuclides exists, the limit established for alpha and beta-gamma apply independently. b. As used in this table, dpm (disintegrations per minute) means the race of emission by radioactive material as determined by - 19

l correcting the counts per minute observed by appropriate detector for background, efficiency, and geometric factors associated with the instrumentation. Measurements of average contaminant should not be averaged over c. more than 1 square meter. For objects of less surface area, the average should be derived for each such object. The maximum contamination level applies to an area of not more d. than 100 square centimeters. 1 of removable radioactive material per 100 square The amount e. centimeters of st.rface area should be determined by wiping that area with dry filter or soft absorbent paper, applying moderate and assessing the amount of radioactive material on the

pressure, W.en wipe with an appropriate instrument of known efficiency.

removable contamination of objects of less surface area is determined, the pertinent levels should be reduced proportionally and the entire surface,should be wiped. NOTE: This table was excerpted from U.S. Atomic Energy Commission Reg Guide 1.86, " Termination of Operating Licenses for Nuclear Reactors" (b) After decommissioning, the exposure rate at one meter from all surfaces in the facility buildings and outdoor areas shall be 5 uR/hr or less above the background leve'l. Background is as defined in OAR 345-26-020(3). (c) The plan must contain provisions that require removal from the site of all radioactive waste as defined in OAR 345-50-025 on a schedule acceptable to the Council. Spent nuclear fuel and other radioactive materials that must be disposed of in a Federally approved facility may be stored on the site until such a Federally approved facility will take the fuel and these radioactive materials. (d) The plan must contain an acceptable program for e monitoring and controlling effluents to ensure compliance with applicable state and federal limits. l if it This program may be incorporated by reference, has previou, sly been approved by EFSC. (e) The plan must contain a program for radiological monitoring to ensure the environment is not being adversely affected. This program may be incorporated t by reference, if it has previously been approved by EFSC. -

(f) The plan must contain provisions for removal or control of hazardous waste that are consistent with applicable Federal and State regulations. (g) ~An analysis of decommissioning alternatives shall be provided with the plan, satisfactory to the Council. This analysis will describe the bases for the decommissioning alternative selected, and shall include a comparison of SAFSTOR and DECON. The analysis must demonstrate that impacts to public health and safety for the option chosen are bounded by the alternatives analyzed above. The analysis must demonstrate that the alternative chosen protects the environment and the health and safety of the public consistent with State and Federal statutes, rules and regulations. 3) The plan must include an estimate of funding necessary for implementation. The Council shall determine if provisions for funding are adequate to implement the plan. (4) Significant revisions to the decommissioning plan must be reviewed and approved by the Council prior to implementation by the site certificate holder. A revision shall be deemed significant if it involves one of the following items: (a) The potential to prevent the release of the site for unrestricted use; or, (b) A change in the criteria for free release of materials; or, (c) A departure in the methodology for determining background levels to a method not generally accepted by the industry; or, (d) A change in the provisions made for hazardous and/ or radioactive waste material removal; or, (e) A significant change in the types or significant increase in the amounts of any effluents that may be released offsite; or, (f) A significant increase in radiological or hazardous material exposure to site workers or to members of the public, including exposure due to transport of radioactive or hazardous material. (5) If a proposed change in the decommissioning plan other than the estimate of funding necessary for implementation involves an increase or decrease in costs greater than 10 percent of the previous estimation, the Council shall be notified prior to implementation. Revisions and changes to the estimate of funding shall be provided to the department within 30 days. The council shall be notified of such revisions at its next regularly scheduled metting. The Council will retain the right to determine the acceptability of the change prior to implementation. (6) Revisions to the decommissioning plan shall be evaluated ~ter the criteria listed above. Records of all changes and associated evaluations shall be maintained for audit by the Department. Revisions to the plan which are not significant shall be provided to the Department within 30 days. The Council shall be notified of such revisions at its next regularly scheduled meeting. (7) Changes to the decommissioning plan which are mandated by the Federal government may be implemented without prior Council approval. (8) Major Component Removal Prior to Approval of the Decommissioning Plan: (a) No component removal which would entail opening of containment building or spent fuel building walls may be performed without prior Council approval of a detailed plan. (b) On receipt of a plan for component removal which meets the criteria of part (a) of this rule, the Council shall intitiate rulemaking to determine if the plan is acceptable. Component removal which meets the criteria of part (a) of this rule may not be performed prior to Council adoption of rules approving the plan. (c) The site certificate holder's plan for major component removal must meet the following criteria: (i) The proposed component removal will not result in a predicted offsite radiation release in excess of the Environmental Protection Agency Protective Action Guidelines (October, 1991) for offsite protective actions. (ii) In the absence of any accident analyzed in the site certificate holder's safety evaluation, activities related to component removal will not result in radioactive effluents which cause the predicted dose to any member of the public in an unrestricted area to exceed 5 millirem Total Effective Dose Equivalent (as defined in 10CFR20 in effect on March 1, 1994) (iii) The proposed component removal will not adversely impact the potential for unrestricted use of the site after decommissioning. (iv) The proposed component removal will not adversely affect the site certificate holder's ability to comply with any of the standards for the decommissioning plan in part (2) of this rule. (v) The proposed component removal will not result in a net increase in the estimated net present value of the total decommissioning cost. d 4-(vi) Projected individual radiation doses to workers will be as low as reasonably achievable for the proposed removal. Annual Decommissioning Report 345-26-380 NEW RULE (1) General Reporting Obligation: (a) Annual reports covering the previous calendar year's activities shall be submitted to the Department within 120 days of the end of the calendar year. The report shall include the items listed in this rule. (b) To the extent that information required by this rule is contained in reports to other state, federal or local agencies, excerpts from such other reports may be submitted to satisfy this rule. The Council may request full copies of such excerpted reports. (2) Contents of Annual Neport: (a) The report shall include summaries, interpretations, and analyses of trends of the results of the Environmental Monitoring Program and the Radiological Environmental Monitoring Program required by OAR 345-26-320 and 330. It shall also contain the results of analy'ses of all radiological environmental samples and of all environmental radiation measurements taken during the reporting period. (b) The report shall include a financial report which demonstrates the financial qualifications of the owners to perform retirement and decommissioning activities. Changes in the financial plan or status of the financial plan shall be included. (c) The report shall include a summary report on site conditions and the status of decommissioning activities. Spent Nuclear Fuel Storage 345-26-390 NEW RULE, AMENDED AND RENUMBERED FROM 345-26-145 (1) purpose: (a) Storage of spent nuclear fuel at a nuclear power plant is an interim measure; otherwise utilities and residents of Oregon would face the financial burden of maintaining, operating, f and safeguarding the on-site storage facilities indefinitely, (b) The purpose of this rule is to cooperate with the federal government in accordance with Oregon's siting policy in ORS 469.310 to ensure the safety of interim on-site storage and to ensure spent nuclear fuel will not be an undue financial burden to utilities or people of Oregon. i

a (2) Capacity and Safety Standards: Storage of spent nuclear fuel up to 791 complete and partial fuel assemblies and containers with nuclear fuel materials in the spent fuel facility at the site of a nuclear power plant by a site certificate holder which has executed a contract with the United States of America pursuant to 42 U.S.C. 10101, as amended from time to time, shall be deemed a permitted use of the site pending transfer of spent nuclear fuel to the U.S. Department of Energy provided that: (a) Storage facilities are designed to maintain discharges of radiation, chemicals, and heat within the limits specified in the Nuclear Regulatory Commission license and National Pollutant Discharge Elimination System permit, (b) Storage facilities are designed such that in case of accidents off-site radiation levels will not exceed the Environmental Protection Agency Protective Action Guidelines (October, 1991) for offsite protective actions. (c) The facility may not be used to store any spent nuclear fuel other than that generated at the facility. (3) Approval of Alternative Spent Nuclear Fuel Storage: i Spent Nuclear Fuel shall be stored only in the Trojan Spent Fuel Pool (SFP). Storage of spent nuclear fuel in any other type of facility shall require the prior adoption of rules by the i Council allowing the specific type of proposed facility. Publications: The publication (s) referred to or incorporated by reference in this rule'are available from the office of the Energy Facility Siting Council. Stat. Auth: ORS Ch. 469 Hist.: NTEC 9, f. 2-13-7S, ef. 3-11-75; EFSC 4-1983, f. ef. 12-20-83 b.

& ol ,rego1-. DEPARTMENT OF ENERGY Date: October 3, 1994 Persons Interested in Trojan Component Removal To: From: Adam Bless subject: Proposed Rule Concerning Trojan Large Component Removal The Oregon Department of Energy (ODOE) has written a proposed rule approving the Portland General Electric (PGE) plan for Large Component Removal (LCR). This p:lcposed rule would allow PGE to remove the Steam Generators and Pressurizer from the Trojan site for permanent disposal. PGE submitted this plan for EFSC approval on July 7 1994. CAR 345-26-370 states that PGE cannot remove these components without prior EFSC approval via a rulemaking process. The proposed rule is attached. ODOE has written the proposed rule in consultation with a Special Advisory Group which included PGE representatives, elected officals from the local community and members of public interest groups. A hearing is scheduled for October 24, 1994 at 1:00 P.M. h. he Tigard Water District. The hearing will be held before the Trojan subcommittee of the Energy Facility Siting Council. F.nclosed is a copy of the hearing notice as it appeared in the October 1 1994 edition of the Oregon Bulletin. Samara Roberts Covernor C DCENSING~ k_' O 1994

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4 s P orosed Rule for Troian Large Comoonent Removal NOTE: This entire rule is new. Ihe four Steam Gen rnte and the.Pra"* r may be removed .345-26-370(9) wwent building trad shipped offsite for perm,-t disposal at nn from the Trojan wu approved low level radioactive waste cCsposal facility prior to Council appro Decommissioning Plan, provided that: (a) The removal is performed in accordance with the "Large Component Rem submitted by Portland General Electric on July 7,1994. (b) Components removed through the Containment Building as descnted in th are limited to those described in the "Lari;e Component Removal Plan". PGE shall verify prior to removal of each component from the industrial area that (c) the disposal facility is available to receive the component and that the river is a for transportation. Planmng to provide mnnngement and coordination with the Oregon Department (d) of Energy, the U.S. Coast Guard, Columbia County Emergency Services, the Oregon Health Division, and the Oregon Division of Emergency Meagement has been completed and approved by the Oregon Department of Energy. Activities related to handling, packaging, and preparation for transportation of (e) radioactive components are performed in accordance with PGE's NRC - approved Quality Assurance Plan (PGE 8010). The Energy Facility Siting Council has reviewed and approved PGE measures to (f) ensure security of the Spent Fuel during the contponent removal process. The Oregon Department of Energy has reviewed and approved the Radiologica (g) Environmental and Effluent Monitoring Plan submitted in accord with OAR 345-26-330. PGE shall verify that the Contninment Opening Door is closed and that the (h) Contninment Purge System is operated as assumed in the accident analysis submitted support of the Large Component Removal Plan throughout any large compone inside containment. PGE shall obtain NRC approval of the proposed component packaging in accord (i) with Title 10 Part 71 of the Code of Federal Regulations. PGE shall preside evidence to the Department that the NRC has approved the PGE plans for packaging the components prior to transporting the first component out of the containment.

c ENERGY FACILITY SITING COUNCIL RULEMAKING ON TROJAN LA.RGE COMPONENT REMOVAL PROJECT TOM WAJ T, GENEPAL MANAGER TECHNICAL FUNCTIONS COMMENTS FOR PORTLAND GENERAL ELECTRIC OCTOBER 24,1994 When Ponland General Electric (PGE) closed the Trojan Nuclear Plant, PGE made a commitment to the citizens of Oregon that the plant would be decommissioned in a safe, timely and cost-effective manner. The large component removal project is the first step in meeting that commitment. The Trojan decommissioning plan is in the final stages of prepamtion and will be submitted to the Council and the Nuclear Regulatory Commission (NRC) later this year. It is expected to take one to two years for the approval of the plan. Through 1995, very favomble rates are available for disposing oflow-level radioactive material. If PGE can dispose of components from the plant during this period, signiEcant cost savings can be achieved. In addition, PGE still has a group of very knowledgeable people at the plant who can efficiently handle the disposal project. The use of these people will result in funher savings. The total cost savings by performing-the large component removal project before 1996 is estimated to be in excess of four million dollars. The removal and disposal of the steam genemtors and pressurizer has been performed at the Yankee Rowe Plant. Furthermore, removal of steam genemtors has been completed at several operating nuclear plants as a pan of steam generator replacement projects. Completing this large component removal project at Trojan will give the Trojan personnel who will perform and manage the eventual decommissioning work additional valuable experience in decommissioning activities. This experience will provide added assurance that the final decommissioning will performed safely and cost-effectively. In July 1994, PGE submitted the request to perform the large component removal project and the plan describing the project (PGE-1062). Since that time, the Oregon Department of Energy's consultant (TAC) has reviewed the plan and found that it meets the Council requirements for approval. In addition, PGE has panicipated in the Special Advisory Group that Page 1

?. met several times to review the project, to ask questions of PGE, and to provide input to the Depanment and the Council on the proposed mie being discussed today. In addition to responding to TAC's requests for information about the project, PGE has also responded in writing to questions and data requests from the Don't Waste Oregon representative on the Special Advisory Group as well as other Special Advisory Gmup members. PGE requests that the Energy Facility Siting Council adopt the mle allowing the large component removal project to proceed. PGE suggests, however, that four clarifying revisions to the proposed rule be included. These changes are described below and shown in strikeout for deletions and double underline for additions: 1. Pamgmph (d) should be revised to clarify that the management and coordination planning should be completed prior to the shipment of the components. Currently, the proposed rule does not specify by what time the planning is to be completed. Thus for clarity, the following revision to the mle is recommended: "(d) Prior to the shipment of the components, planmng to provide management and coordination with the Oregon Department of Energy, the U. S. Coast Guard Columbia County Emergency Services, the Oregon Health Division, and the Omgon vivision of Emergency Management has been completed and approved by the Oregon Depanment of Energy " 2. Paragraph (e) currently requires the work associated with the transportation of the radioactive components will be performed in accordance with an NRC approved quality assurance program. While the NRC specifies the content of the quality assurance program and approves any significant revisions to the program, minor revisions to the program may be made by PGE without NRC approval. These revisions must be submitted to the NRC so they are aware of them. The NRC can reject changes made in this manner, if they believe they are not in accordance with the regulations. Therefore for clarity, the following revision to the rule is recommended: Page 2

4 "(e) Activities related to handling, packaging and preparation for transportation of radioactive components are performed in accordance with PGE's NRC approved 10CFR50. Appendix B (effective as of 1994) Quality Assurance Plan (PGE 8010). 3. Paragraph (j) requires that PGE obtain a dredging permit from the Oregon Division of State Lands and the U.S. Army Corps of Engineers. To ensure clarity on the timing of this requirement. the following revision to the rule is recommended: "(j) Prior to commencement of dredning operations. PGE shall obtain a dredging permit from the Oregon Division of State Lands and U.S. Army Corps of Engineers." 4. Paragraph (k) requires that PGE monitor the perimeter of the industrial area to assure members of the public are not unnecessarily close to the preparation area for the large components. To ensure clarity on this requirement, the following revision to the rule is recommended: "(k) The perimeter of the industrial area near the component preparation ama shall be periodically monitored to ensure that members of the public are not within the these owner controlled areas while the components described in the I2rge Component Removal Plan are stored in the industrial area." l I would like to summarize for the record the actions the NRC is taking in their regulatory oversight of the large component removal project. On September 16,1994, the NRC issued a letter to PGE which confirmed the NRC regulatory process for the large component removal project. A copy of this letter is attached. On October 13, 1994, the NRC conducted an audit of the PGE evaluation of the ability of PGE to perform the work without prior NRC approval. (This evaluation is called the 10CFR50.59 evaluation.) The audit confirmed the acceptability of the PGE evaluation. It is expected that the NRC will conduct on-site inspections of the large component removal work as it proceeds. Page 3

.A e .e Thank you for the opponunity to comment on the proposed rule. PGE recommends adoption i of the rule with the clarifying revisions recommended above. f [ a b e e I r Page 4 I

o GENERAL MANAGS T A T E S M A N J O U R ~ MONDAY TECHNICAL FUNCTIONS E E October 17,1994 N ,, _4

00 Salem, Oregon c:

Officers Bob Hall "g Editorials = wait My longtime friends, Joc and Syd Synch, came over and I was just returnmg e e a e .P O kitchen with beverages w spoke some words which would arouse Syd. He sali = = = V V once approached by some ":0 ~:Exe "="rO an acar: now , rad,uates abou 8 g playing sented his best professo,a n h dd Let's get the We have a hunch that Don't Waste Or- {"",ce nspo$png a e Q [3 Nuclear foesclosed Trojan nu-egon isa t concerned only about the radi-13en.- Tdon't want the clear power plant oactivity of the generators. Its stand now Jock, often perplexed, s dismantled and appears to be mostly anti-PGE. The bat-plexed once again. "Why, w generators out of our hair as tle has gone on so iong that the target that have to do with it7-FernOVed yet. quick 2y as pos-became not only to close Trojan but also "It has everything to do Jock. Newcomers to The sible. to punish the utility that operated it. Portland Gen- , Don't Waste Oregon also has opposed Nj,I ht d lo t1ei eral Electric wants the state s permis-at least one other proposal for an alter-too.- sion to speed up by several years the native source of power generation, a nat-Syd gave Jock an up-a: first step m decommissioning the plant. ural gas-fired generator, supposedly on once-over and said, "Besii But instead of supporting and encourag-grounds that the extra power was not don't have the mentality The Citadel." ing PGE, the group that fought for years needed. Everyone else would disagree. Jock appeared to be c to close down Trojan now is urging a go-With Trojan closed and our dams pro- ,,What do you mean, I do slow approach. Friday, it filed a suit t ducing less power because of salmon-stop the removal of the plant's steam rescue plans and the drought, the North-ht w a[s i gf s hoc generapors. west will need all the electrical power it " Jock, Jock, would I ever That s a switch. At one time Don,t can find. persions upon your ment. Waste Oregon wanted Trojan gone the We urge the state to give its go-ahead bilities? You might have next day, and now it want, PGE to hold and let PGE remove the seven-story gen-ac demic star at The Ci off on removal of four giant steam gen-meant y u have never i erators as soon as possible. PGE has ac-mindset to go to a place 1 erators for a few more years because of cess to all the expertise it needs to han* Citadel. For example, you its concerns about radioactivity. die the radioactive generators at no risk wear your shirt out or at b ' PGE has a reason for wanting to re-t w rkers or the pubbc. way out. move and get rid of the generators next ? year instead ofin 1998. It could save It already has documented all the evi-The Citadel Jock, a about $4.5 million by disposmg of them dence it needs to press legal action before Hanford's rates merease in Jariu-against Westinghouse, the manufacturer ary 1996. of the generators. So dumping the gen-Saving money is a good reason to erators at Hanford won't hurt the b T%I-be - - hurry - for PGE and ratepayers. An-utility's case. Ifit had to keep the gen-M other good reason is to get the plant out erators on hand until the trial - as ~ g. i of the way at the earliest time so that we Don't Waste Oregon apparently wants - can use the property for another power-we co'r'd be waiting 10 or 20 years to get generating system, probably a natural rid ofTrojan. M gas generator. Let the dismantling begin - now. \\/ErriX Tler':s re-e ector t', V a M Kevin Mannix lution. N He is one of deserves re-Anvene with more ideas and more en- .V}}