ML20199J564

Application for Amends to License NPF-1,deleting Security Plan Requirements of 10CFR50.54(p) & Part 73 for Trojan Plant After Spent Nuclear Fuel Is Moved to Proposed ISFSI Area

ML20199J564
Person / Time
Site:	Trojan  File:Portland General Electric icon.png
Issue date:	01/29/1998
From:	PORTLAND GENERAL ELECTRIC CO.
To:
Shared Package
ML20199J554	List: ML20199J548 ML20199J564 ML20199J580
References
NUDOCS 9802050343
Download: ML20199J564 (11)

Text

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r A1TACilMENT I 10 CFR PART 50.54(p) AND PART 73 EXEMPTION 1

l LICENSE CilANGE APPLICATION (LCA)?43 DELETION OF TROJAN SECURITY PLAN (Topical Reports PGE 1017 and PGE 1024) 9902050343 900129 PDR A[/1CK 05000344 W PD81 j

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TABLE OF CONTENTS

1. IIACKGR6tIND AND REASON FOR CllANGE 2 i

2. DESCRIPTION OF CllANGE 5

3. NO SlONIFICANT llAZARDS CONSIDERATION DETERMINATION 6 4 SCllEDULE CONSIDERATION 7 i

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1. llackground and Reason for the Exemption and License Change Existing Security Requirements The Federal Regulations [10 CFR 50.54(p) and 73.55] require that licensees establish ar.d maintain an onsite physical protection system and security organization which will have as its objectue to provide high assurance that activities involving special nuclear material are not inimical to the common defense and security and do not constitute an unreasonable risk to the public health and safety.

On May 5,1993, the NRC granted a Possession Only License for the Trojan Nuclear Plant. With the spent fuel stored in the Spent Fuel Pool, the spectrum of postulated radiological sabotage-related events had been greatly reduced. On July 26,1993, Portland General Electric Company (PGE) submit ed the Trojan Nuclear Plant Security Plan (Defueled Condition) to the NRC. The Plan was approved and issued as the Trojan Nuclear Plant Security Plan (Defueled Condition),

Revision 40, on Septensber 30,1993.

The permanently shutdown and Defueled condition of Trojan allowed a consolidation of the Security Plan that focused on the protection ofirradiated fuel in the Spent Fuel Pool, in addition, the Plan changes contained elements to prevent theft of Special Nuclear Material (SNM) and ensured that security related events do not occur which could result in radiological exposure or contamination of individuals at Trojan or the genml public.

A review of bounding sabotage events at the time of the submittal, established that, while there were radiological sabotage scenarios that could occur, an act of sabotage could not .esult in a radiological release in excess of 10 CFR 100 or the Environmental Protection Agency Protective Action Guideline (EPA-400 PAG) limits. The systems and procedures established in the Troja:,

Security Plan (Defueled Condition) were designed to ensure that radiological sabotage is a highly improbable event.

Based on the pennanent shutdown and Defueled condition of Trojan and the resuhs of the subsequent safety and sabotage event analysis, several requirements of 10 CFR 73.55 were 2

determined to no longer be applicable. A commensurate redaction in the level of security was appropriate and did not decrease the effectiveness of the Trojan Security Plan. The currently revised Trojan Nuclear Plant Security Plan describes the overall security policies and specific criteria followed by personnel entering the Industrial and Protected Areas of the Trojan Nuclear Plant. The performance objective of the revised Trojan Security Plan affirmed that the Portland Genaral Electric Trojan Nuclear Security Orga ization provides high assurance that activities involving the long tenn shutdown of Trojan in a Defueled condition with fuel in the Spent Fuel Pool is not inimical to the commt . ' 'nal defense and security, and did not constitute an unreasonable risk to the public health mJ safety.

ISFSI Security Requirements On M ah 26.1996, the Trojan independent Spent Fuel Storage Installation (ISFSI) Security Pir.n iPGE 1073) was submitted to the NRC requesting review and approval (reference VPN-0; 3 96, dated March 26,1996). On August 15,1996, PGE submitted a revision to the proposed ISFSI Security Plan to the NRC Staff (reference VPN 05196). On November 20,1996, the NRC conditionally approved the Trojan Independent Spent Fuel Storage Installation (ISFSI)

Security Plan, which incorporates the ISFSI Training and Qualification Plan and Contingency Response Plan. The NRC Staff approval conteined a condition; that the NRC StafTapprove a license to operate the Trojan ISFSI in accordance with 10 CFR Part 72 (reference Docket No. 72-17). The Trojan ISFSI Security Plan was developed to meet the requirements of 10 CFR 72 Subpart II, " Physical Protection," and was prepared using the guidance provided in NUREG-1497," Interim Licensing Criteria for Physical Protection of Certain Storage of Spent Fuel,"

dated November 1994. Deviations from NUREG 1497 were based on site specific conditions and were considered to provide a commensurate level of security.

The ISFSI is located on the Trojan Nuclear Plant (TNP) site which is in Columbia County, Oregon, and which lies along the Columbia River approximately 42 miles north of Portland, Oregon. The ISFSI, which establishes a stand alone Protected Area (PA),is located in the  ;

northeast corner of the TNP site. The ISFSI consists of a reinforced concrete pad supporting up to 36 Sierra Nuclear Corporation's Transtorm Storage Systems. The Transtorm Storage System is a dry storage system which utilizes a ventilated concrete cask and a seal welded stainless steel basket to safely tore spent fuel.

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The Trojan ISFEl Security Plan establishes the physical protection system and security organization wit h the objective of providing high assurance for the protection of the public health and safety and tlie common defense and security. This is achieved through the use of trained personnel, physical barriers, access controls, intrusion wtection, communications, contingency response, and liaison with the appropriate law enforcement agency. The provisions of the Trojan ISFSI Security Plan will become elrective prior to the movement of the first loaded storage j system outside the Fuel Iluilding and placement in the ISFSI.

liasis for Security Plan Deletion It is projected that the last dry fuel storage cask will be moved out of the Fuel lluilding and into the ISFSI Protected Area about November 30 1999. With the completion of the fuel movement into the ISFSI, there will no longer be any special nuclear fuel left in the Trojan spent fuel pool, containment, or the fuel building. The potential for radiological sabotage or diversion of nuclear fuel is, therefore, eliminated. PGil, tnerefore, requests exemption, pursuant to 10 CFR 50.12, from the requirements of 10 CFR 50.54(p) and 10 CFR 73 for the Part 50 Licensed area of the Trojan facility.

The Federal Regulation [10 CFR 50.54(p) and 73.55] requirement that licensees establish and maintain an onsite physical protection system and security organization which provides a high degree of assurance that activities involving special nuclear material are not inimical to the common defense and security and do not constitute an unreasonable risk to the public health and safety are satisfied by the removal of the fuel to the ISFSI. The remainder of the Trojan facility site, licensed under 10 CFR 50, will no longer pose an unreasonable risk to the public health and safety, in addition, the exemption and Lcnse change will permit more effective utilization of the finite decommissioning financial resources. Funds which would otherwise be used to support security requirements for the Trojan Plant, would be available to perform decommissicning operations.

Decommissioning operations would no longer be constrained by security requirements that are not meaningful to the protection of the public health and safety. The decommissi " ting activities would, therefore, be more efficiently performed, thereby, conserving available decommissioning funds.

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2. Description of Exemption Request and License Change The purpose of the Security requirements is to provide a high degree of assurance that activities involving Special Fuclear hiaterial are not inimical to the common defense and security and do not constitute an unreasonable risk to the public health and safety (10 CFR 73.55a). This requires defending against perceived threats; the Int ( mal Threat (Employce) and the External Threat (Design Basis Threat). These requirements t.re based on the presence of Special Nuclear hiaterial (SNhi) and the transfer of the SNhi from the spent fuel pool to the ISFSI removes the need for these requirements. PGE requests exemption, pursuant to 10 CFR 50.12, from the requirements of 10 CFR 50.54(p) and 10 CFR 73 for the 10 CFR Part 50 Licensed area of the Trojan facility. The potential for radiological sabotage or the diversion of special nuclear material will no longer exist afler the fuel has been moved to the ISFSI area. The related security requirements, therefore, should logically be removed as requirements for the remaining 10 CFR

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Part 50 licensed area of the Trojan Plant. Application of the regulation in these particular circumstances would not suve the underlying purpose of the rule and is not necessary to achieve the underlying purpose of the rule.

Afler the fuel is removed to the ISFSI, the remaining Trojan plant area, though licensed under 10 CFR Part 50, vill be comparable to many source and byproduct licensees, in terms of the level of security needed to protect the public health and safety. As such, the continued application of 10 CFR Part 73 security requirements would force the Trojan facility to expend significantly more ftmds for security than other facilities similarly situated. Compliance with the rule would, therefore, result in costs that are significantly in excess of those facilities that are similarly situated.

In light of the above movement of all fuel from the Fuel and Auxiliary Building, ano i mplementation of the 10 CFR Part 72 ISFSI Security Plan (PGE 1073), PGE requests n License Amendment pursuant to 10 CFR 50.90 to delete the Safeguards requirements specified in the Part 50 license of the Trojan Nuclear Plant (Section 2.0), Technical Specification 5.7.1.1,(b) and.

specifically the requirements of the Trojan Nuclear Plant Security Plan (Defueled Condition)

(PGE 1017) and the Trojan Nuclear Plant Security Force Training and Qualification Plan (PGE 1024).

Attachment 11 contains a mark up of the er fected License page and Tec6ical Specification page.

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. 3. No Significant liarards Consideration Determination In accordance with the requirements of 10 CFR 50.00," Application for amendment oflicense or construction permit " this license amendment request is judged to involve no significant hazards consideration based upon the following.

1. The proposed license amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The physical structures, systems and components of the Trojan Nuclear Plant and the operating procedures for their use are unaffected by the proposed change. The proposed elimination of the security requirements for the 10 CFR Part 50 license,is predicated on approval of the Trojan ISFSI Security Plan (PGE 1073) which will be coincident with issuance of a 10 CFR Part 72 license and upon completion of the transfer of all nuclear fuel from the spent fuci pool to the ISFSI. The planned 10 CFR 72 licensing controls for the ISFSI will provide adequate conFdence that personnel and equipment can perform j satisfactorily for normal operations of the ISFSI and respond adequately to abnormal events / accidents. The proposed Trojan ISFS1 Security Plan (PGE 1073) will also provide confidence that security personnel and safeguards systems will perform satisfactorily to c

ensu e adequate protection for the storage of spent nuclear fuel. Therefore, the proposed 10 Ci'R Part 50 amendment dees not involve a significant increase in the probability or consequences of an accident preslou-ly evaluated.

2. The proposed license amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed change is security related, and as such, has no direct impact on plant equipe ent or the procedure for operating plant equipment and, therefore, does not create the possibility of a new or different kind of accident from any accident previously evaluated. Because the proposed ISFSI area will be segregated from the 10 CFR Part 50 6

licensed area, licensed security activities under the 10 CFR Part 50 license will no longer

• l be necessary after all the nuclear fuel has been moved. The planned 10 CFR 72 licensing controls fbr the ISFSI area will provide adequate confidence that personnel and equipment can perform satisfactorily for normal operat ions of the ISFSI and respond adequately to nomnl events / accidents. Moreover, the ISFSI will be physically separate from the Trojan Nuclear Plant structures and equipment. Therefore, the proposed 10 CFR Part 50 license amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. The proposed license amendment does not involve a significant reduction in a margin of safety. -

l The assumptions for a fuel handling and other accidents are not affected by the proposed l license amendment. Because the proposed ISFSI area (that will contain the nuclear fuel) will be segregated from the 10 CFR Part 50 licensed area, licensed security activities l under the 10 CFR Part 50 license will no longer be necessary. The planned 10 CFR 72 licensing controls for the ISFSI area will provide adequate confidence that personnel and equipment can perform satisfactorily for normal operations of the ISFSI and respond adequately to abnormal events / accidents. Also, the ISFSI will be physically separate from the Troja- Nuclear Plant structures and equipment. Therefore, the proposed 10 CFR Part 50 license amendment does not involve a s:gnificant reduction in a margin of safety.

4. Schedule Consideration it is requested that the proposed amendment be made immediately effective upon the transfer of the last cask of spent fuel from the spent fuel pool to the ISFSI. It is projected that this licensing action will be needed no later than November 30,1999. Earlier action by the NRC Staff would facilitate timely implementation, therefore, NRC action is requested by August 1998. Early approval of the requested Exemption and License Amendment will permit orderly implementation of procedural changes, stalTallocations, and budgetary and decommissioning planning adjustments.

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ATI'ACilMENT 11 LICENSE PAGE CIIANGES

(5) The licensee may procesd with and is required to compic+.e the modifications identifit:d in Paragraphs 3.1.1 through 3.1.18 of the NRC Fire Protection Safety Evaluation Report on the Trojan Nuclear Plant dated March 22, 1978. These modifications shall be completed by the end of the second refueling outage of the Trojan facility and prior to return to operation for Cycle 3. In addition, the licensea shall submit the additional information identified in Table 3.2 of this Safety Evaluation Report in accordance with the vehedule contained therein. In the event these dates for submittal cannot be met, the licensee shall submit a report explaining the circumstances, together with a revised schedule.

(6) Primary Shieldino Modification The licensee is authorized to nodify the primary shielding design as described in PGE letter dated April 22, 1977, as supplemented and amended by letters dated September 22 and 23, 1977, December 22, 1977, January 4 and 24,1978, March 20, and April 4, 1978.

(7) Seent Fuel Assembly Shionino Cask The licensee shall not move a spent fuel assembly shipping cask into the Fuel Building.

D. The licensee shall fully implement and maintain in effect all provi-sions of the Commission-approved physical security, guard training and l

qualification, and safeguards contingency plans including amendments made pursuant to provision of the Miscellaneous Amendments and Search ar.d to the Requirements authority of 10 CFR to 10 CFR 50.90 73.55 and (5150.54(p).

10 CFR FR 27817Theand p 27821) lans, which contain Safeguards Information protected under 10 CFR 73.21, are y entitled: " Trojan Nuclear Plant Security Plan', with revisions sub-mitted through October 7,1988; " Trojan Nuclear Plant Security Force Training and Qualification Plan", with revisions submitted through j

. June 10, 1988; and " Trojan Nuclear Plant Safeguards Contingency Plan", \

with revisions submitted through October 7, 1998. Changes made in accordance with 10 CFR 73.55 shall be implemented in accordance with /

the schedule set forth herein.

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4 (5) The licensee may proceed with and is required to complete the modifications identified in Paragraphs 3.1.1 through 3.1.18 of the NRC Fire Protection Safety Evaluation Report on the Trojan Nuclear Plant dated March 22,1978. These modifications shall be completed by the end of the second refueling outage of the Trojan facility and prior to return to operation for Cycle 3. In addition, the licensee shall submit the additional inform,ation identified in Table 3.2 of this Safety Evaluation Report in accordance with the schedule contained therein. In the event these dates for submittal cannot be met, the licensee shall submit a report explaining the circumstances, together with a revised schedule.

(6) Primary Shielding ModiftcauoD The licensee is authorized to modify the primary shielding design as described l in PGE letter dated Apal 22,1977, as supplemented and amended by letters

dated September 22 and 23,1977, December 22,1977, January 4 l and 24,1978, March 20, and April 4,1978.

(7) Soant Fuel Assembly Shioning Cask Deleted (Amendment 196)

(8) Fire Protection The licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in PGE 1012, "Trcian Nuclear Plant Fire Pratectior. Plan' and as approved in the SER datoJ September 22,1993 subject to the following provision:

The licensee may tr.>ke changes to the approved fire pro,'ection program w thout prior approval of the Commission only if those changes would na* Fversely impact the safe storage of irradiated fuel or mcrease the likelihood of an offsite release of radioactive material due to a 5.

(9) Soent Fuel Pool Debris PrqgesalDg The licensee is authorized to process spent fuel pool debris in accordance with PGE letter dated October 23,1996.

D. (Intentionally deleted) l

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