ML20207C698

1998 Annual Rept for Trojan Nuclear Plant. with

ML20207C698
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	12/31/1998
From:	Quennoz S PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
PGE-1015-98, VPN-010-99, VPN-10-99, NUDOCS 9903090082
Download: ML20207C698 (52)

Text

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I Portland General Electric Company Trojan NuclearPlant 71760 Columbia RurHay Rainier OR 97048 (503)536 3713 1

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February 24,1999

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VPN-010-99 l l

Trojan Nuclear Plant Docket 50-344 License NPF-1 l l

U.S. Nuclear Regulatory Commission J

ATTN: Document Control Desk )

Washington, DC 20555 l l

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PGE-1015-98. " Annual Reoort of the Trojan Nuclear Plant"

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The enclosure to this letter provides one copy of Portland General Electric Company's " Annual Report  ;

of the Trojan Nuclear Plant" for the calendar year 1998. This report is submitted in accordance with the j requirements of 10 Code of Federal Regulations 50.59(b)(2) and Trojan Technical Specification 5.8.1. l l

Sincerely,

,qrmy --

Stephen M. Quennoz Vice President, Nuclear l and Thermal Operations

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Enclosure \

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c: ' D. Stewart-Smith, OOE' l R. A. Scarano, NRC Region IV L. H. Thonus, NRC, NRR -

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9903090092 991231 7 k;%

PDR ADOCK 05000344 P / .

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Connecting People, Power and Possibilities #

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i 1998 ANNUAL REPORT J

l for . l TROJAN NUCLEAR PLANT I

i Docket 50-344 License NPF-1

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. PORTLAND GENERAL ELECTRIC COMPANY  !

l 121 S. W. Salmon Street Portland, Oregon 97204 i

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' TABII OF CONTENTS  !

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INTRODUCTION &

SUMMARY

OF OPERATING EXPERIENCE . . . . . . . . . . . . . . . . . . ii Annual Personnel Exposure and Monitoring Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1  :

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2. Changes, Tests, and Experiments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 ,

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I INTRODUCTION The 1998 Annual Report for Trojan Nuclear Plant is submitted in accordance with the requirements of Possession Only License NPF-1, Appendix A, Permanently Defueled Technical ,

Specification 5.8.1 and 10 CFR 50.59(b)(2).

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i SUMM,'.RY OF OPERATING EXPERIENCE IN 1998 i Throughout the entire year, the plant remained permanently shutdown with the fuel removed from the reactor vessel.

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1. ANNUAL PERSONNEL EXPOSURE AND MONITORING REPORT l Requirement j l

Trojan Possession Only License NPF-1, Appendix A, Permanently Defueled Technical .

Specification 5.8.1.1, requires that an annual report be submitted which includes:

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" Occupational Radiation Exposure Report shall include a '

tabulation on an annual basis of the nuraber of station, utility, and - l other personnel (including contractors) receiving exposures i

> 100 mrem /yr and their associated man-rem exposure according  !

to work andjob functions (e.g., fuel handling, surveillance, '

maintenance and waste processing). This tabulation supplements  !

the requirements of10 CFR 20.2206. The dose assignments to i various duty functions may be estimated based on pocket -  !

dosimeter, thermoluminescent dosimeter (TLD), or film badge -l measurements.- Small exposures totaling < 20% of the individual total dose need not be accounted for. In the aggregate, at least 80%  !

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

Report ,

l l Table 1 lists the number of workers and total exposures greater than 100 mrem per year i and the total exposures by work and job function for the year 1998 based on self-reading

! dosimeter results. The " Total" and " Grand Total" sections of the table are based on self-reading dosimeters.

All work performed for dismantlement and decommissioning was classified as work function "Special Maintenance." All of the contractors for dismantlement and decommissioning activities were classified asjob function " Maintenance." Note that contracted personnel represented 54% of exposed workers and 63% of 1998 reported dose.

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TABLE 1 .

r Sheet 1 of 2 i REPORT ON NUMBER OF PERSONNEL AND MAN-REM l BY WORK AND JOB FUNCTIONS  ;

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No. of Peaal (>100 mrem) Tntal Man R- (>100 mrem) j Station Utility Contract ~ Station Utility - , Contract Work and Job Function Emplovees Employees Workers Emplovees Employees Workers l

' REACTOR OPERATIONS & SURVEILLANCE i

Maintenance Personnel 0 0 1 0.000 0.000 0.123 i Operating Personnel 0 0 0 0.000 0.000 0.000 'l Health Physics Personnel 0_ 0 0 0.000 0.000 0.000 l Supervisory Personnel 0 0 0 0.000- 0.000 0.000 i

. Engineering Personnel 1 0 0 0.107 - 0.000 0.000 i

ROUTINE MAINTENANCE -

l Maintenance Personnel 0 0 0 0.000 0.000 0.000

Operating Personnel 0 0 0 0.000 0.000 0.000 ,

l Health Physics Personnel' O O O 0.000 0.000 0.000 j Supervisory Persocnel 0 0 0 0.000 0.000 0.000 '

Engineering Personnel 0~ 0 0 0.000 0.000 0.000 INSERVICE INSPECTIONS Maintenance Personnel 'O O O 0.000 0.000 0.000 l Operating Personnel 0 0 0 0.000 0.000 0.000 Heshh Physics Personnel 0 0 0 0.000 0.000 0.000 s Sup:rvisory Personnel 0 0 0 0.000 0.000 0.000 Engineering Personnel 0 0 0 0.000 0.000 0.000 SPECIAL MAINTENANCE -

Maintenance Personnel , 42 0 73 ' 10.872 0.000 30.071 Operating Personnel 0 0 0' O.000 0.000 0.000 Health Physics Personnel 21 0 1 6.324 0.000 0.143 i Supervisory Personnel: 0 0 0 0.000 0.000 0.000

! Engineerirg Personnel 1 0 1I 0.583 0.000 2.376 i-7 2

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TABLEI Sheet 2 of 2 REPORT ON NUMBER OF PERSONNEL AND MAN-REM BY WORK AND JOB FUNCTIONS 1998 No. of Personnel (> 100 mrem) Total Man-Rem (> 100 mrem)

Station Utility Contract Station Utility Contract Work and Job Function Emniovees Emnlovees Workers Emnlovees Emnlovees Woners WASTE PROCESSING Maintenance Personnel 6 0 0 1.150 0.000 0.000 Operating Personnel 0 0 0 0.000 0.000 0.000 llealth Physics Personnel 0 0 0 0.000 0.000 0.000 Supervisory Personnel 0 0 0 0.000 0.000 0.000 Engineering Personnel 1 0 0 0.204 0.000 0.000 REFUELINd Maintenance Personnel 0 0 0 0.000 0.000 0.000 Operating Personnel 0 . 0 0 0.000 0.000 0.000 llealth Physics Personnel 0 0 0 0.000 0.000 0.000 Supervisory Personnel 0 0 0 0.000 0.000 0.000 Engineering Personnel 0 0 0 0.000 0.000 0.000 TOTAL Maintenance Personnel 48 0 74 12.022 0.000 30.194 Operating Personnel 0 0 0 0.000 0.00') 0.000 llealth Physics Personnel 21 0 1 6.324 0.000 0.143 Supervisory Personnel 0 0 0 0.000 0.000 0.000 Engineering Personnel 3 0 11 0.894 0.000 2.36 GRAND TOTAL 72 0 86 19.241 0.000 32.712 3

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

"(a)(1) The holder of a license authorizing operation of a production or utilization facility may (i) make changes in the facility as described in the safety analysis report, (ii)

' make changes in the procedures as described in the safety j!

. analysis report, and (iii) conduct tests or experiments not  !

described in the safety analysis report, without prior

. Commission approval, unless the proposed change, test or - j experimen? Swolves'a change in the technical specifications -j incorporated in the license or an unreviewed safety . i question.  ;

L (b)(2) The licensee shall submit, as specified in f 50.4, a irport )'

containing a brief description of any changes, tests, and experiments, including a summary of the safety evaluation ofeach... annually..."

Report Section 2 of the Annual Report provides a description of changes, tests, and experiments completed in 1998 in accordance with 10 CFR 50.59 and a summary of the supporting ,

safety evaluation.

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I 199810 CFR 50.59 Annual Report Safety Evaluation Number 96-051 Subjrs.1 -

Document Changes to incorporate the Reactor Vessel And Internals Removal (RVAIR) Project Option Description of Chance. Test. Exneriment The proposed RVAIR project provides for removal of the reactor vessel with the internals intact from the Containment Building for transport and burial. PGE-1061," Trojan Nuclear Plant Decommissioning Plan," PGE-1063," Supplement to Applicant's Environmental Report - Post Operating License Stage," and PGE-1017," Trojan Nuclear Plant Security Plan (Defueled j Condition)," were revised to include the RVAIR project as an option for removing and '

dispositioning the reactor vessel and internals as a single entity. Revised areas of the documents i include waste projections, decommissioning schedule and cost adjustments, and changes to the l Protected Area boundary. The RVAIR project, which received regulatory approval,is scheduled to occur in 1999. The option for dispositioning the reactor vessel and internals by segmentation was retained in the topical reports, i

Summary of Safety Evaluation

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The changes are administrative in nature an'd do not increase the probability of occunence of an )

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

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199810 CFR 50.59 Annual Report Safety Evaluation Number 97-005 Subject i Revision 21 to PGE-8010," Nuclear Quality Assurance (QA) Program," Corporate Management Position Titles  ;

Description of Chanee. Test. Experirutni These administrative changes update the QA Program for consistency with Trojan 10 CFR 50 Technical Specifications (TTS). The revision to Sections 1 and 4 changes PGE corporate management-specific position titles to generic position titles. The changes are consistent with ,

TTS 5.2.1. Organizational structure changes are limited to the scope of changes authorized by J License Amendment 195. The revision to Section I also clarifies the responsibilities of nuclear l support organizations for QA Program implementation.

~ The position ofIndependent Spent Fuel Storage Installation (ISFSI) Manager is included in the revision along with the ISFSI Safety Review Committee (ISRC) functions and responsibilities under 10 CFR 72. These inclusions in Section 1 are consistent with Trojan's License i Application for a 10 CFR 72 License currently under review by the NRC Staff. Changes to Appendix B add ISRC biennial assessment requirements and 10 CFR 72.48 records.

The revision also includes administrative changes to correct typographical errors in the Glossary Section and update the definition of quality-related consistent with Trojan Environmental  ;

Technical Specifications, j i

These changes were determined to be in accordance with 10 CFR 50, Appendix B, Criterion I .

and II, of the Commission's regulations. The Nuclear Oversight Department still reports to the I management position (Trojan Site Executive and Plant General Manager) that has corporate  ;

responsibility for overall nuclear safety and retains authority and organizational freedom to i perform their quality assurance function.

l Summary of Safety Evaluation l These changes are administrative in nature and do not increase the probability of occurrence of l an accident previously evaluated in the DSAR. These changes do not affect any plant equipment

, or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and do not result in any degradation in the reliability of structures, systems, or components.

1 These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an )

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accident or malfunction of equipment important to safety previously evaluated in the DSAR,(2)  !

a possibility for an accident or malfunction of a different type than any evaluated previously in l the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical ,

specifications is not reduced.  !

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199810 CFR 50.59 Annual Report l

Safety Evaluation Number 97-021

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Subiect Defueled Plant Modification Request (DPMR)97-022, Detailed Construction Package (DCP) 1,

" Modify Containment Penetration to Support Use of a Portable Air Cooler" l Description of Cha.nge. Test. Experiment This DPMR modifies a spare Containment penetration to connect a portable air conditioning unit to supply conditioned air to a portion of Containment during hot weather. The modification involves removing the welded end caps from the outside of the wall and installing duct adaptors to each end of the penetration. A security barrier and backdraft damper are incorporated into the  !

design to meet Program requirements ofless than 96 square inches for an opening. PGE-1012,

" Fire Protection Plan," is amended (Amendment 19) to incorporate the Demineralizer Building smoke detectors and modification of ' 'ontainment penetration 145. ,

l Summary of Safety Evaluation These changes do not increase the probability of occurrence of an accident previously evaluated in the DSAR. A new effluent flow path to outside Containment is not generated due to a backdraft damper installed at the penetrations to prevent flow in that direction. These changes do not affect the processes and procedures for responding to an equipment malfuhetion. These changes do not result in any degradation in the reliability of structures, systems, or components.

The modifications are located in a remote area from safety related equipment and cannot impact ,

the safe storage ofirradiated fuel. These changes do not constitute a significant increase in fire i hazard or fire loading to the structures. j l

These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. Therefore, these changes do not involve an unreviewed safety question

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

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199810 CFR 50.59 Annual Report Safety Evaluation Number 97-023 Subject DPMR 97-012, DCP 5," Install a Rollup Door in the Fuel Building Crane Bay" Description of Change. Test. Experiment Door #177 is replaced by a roll-up door in the Fuel Building crane bay east wall at the 45 foot elevation to facilitate vehicle and equipment access for occommissioning projects. The new door is locked and alarmed to meet Security Plan barrier requirements. This portion of the Fuel Building wall is not a fire boundary. PGE-1017," Permanently Defueled Security Plan (Defueled Condition)," was revised (Revision 49) to incorporate the change. i Summary of Safety Evaluation These changes do not increase the probability of occurrence of an accident previously evaluated in the DSAR and do not impact the seismic structure of the Building. These changes do not )

affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and do not result in any degradation in the reliability of structures, systems, or l components. The changes do not affect the safe storage ofirradiated fuel in the Spent Fuel Pool.

1 These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. The new door is outside the safe load path for the ISFSI casks. l Therefore, these changes do not involve an unreviewed safety question because, (1) there is no l increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

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199810 CFR 50.59 Annual Report Safety Evaluation Number 97-024 Subiect DPMR 97-002, DCP 2," Deactivate Component Cooling Water System (CCWS) 'B' Train Component Air Coolers (CACs)"

Description of Change. Test. Experiment The 'B' train CACs, associated CAC valves, miscellaneous resistance temperature detectors, and selected PRM-1 Containment sampling valves are deactivated to support decommissioning efforts fc component removal. DSAR Figure 3.3-2 is revised and Section 3.3.3 descriptions of the CCWS are revised to reflect the changes (Revision 6).

Summary of Safety Evaluation The CCWS no longer performs any safety related functions, but is classified as "important to the safe storage ofirradiated fuel." A smaller pump, P-210D, was previously installed in the 'B' train CCWS (under DPMR 94-008, DCP 3) for removal of decay heat from the Spent Fuel Pool.

This pump functions as the primary source for removal of decay heat from the Spent Fuel Pool and does not require a recirculation loop (i.e., does not require a flowpath through the CACs for recirculation). Affected components are no longer required and, therefore, removal does not

! degrade the reliability of the CCWS to supply cooling water to the Spent Fuel Pool heat exchangers or increase the probability oflosing CCWS cooling water flow. These changes do not increase the probability of occurrence of an accident previously evaluated in the DSAR.

These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes do not result in any degradation in the reliability of

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

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199810 CFR 50.59 Annual Report Safety EvaluatiotNumber 97-025 J

l Subiect DPMR 97-002, DCP 4," Containment Sump Deactivation"  !

Description of Change. Test. Experimtat The Containment Building portion of the Dirty Radioactive Waste System (DRWS) is deactivated and replaced with a temporary system. Sump pumps, P304A and P-304B, are l removed along with most of the Containment sump discharge piping. The temporary system l installed includes portable sump pumps and a hose connection on the discharge piping. DSAR Section 5.3.2.2 and Figure 5.3-2 are revised (Revision 6) to denote these changes.

Summary of Safety Evaluation These changes do not increase the probability of occurrence of an accident previously evaluated l in the DSAR. The DRWS does not perform any safety functions, therefore, the changes do not i

affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and do not result in any degradation in the reliability of structures, systems, or i components. The portion of the DRWS outside Containment is not affected by these changes, l thefefore, waste flow entering the DRWS from Containmenl is processed and routed in accordance with the installed design.

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

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J Safety Evaluation Number 97-026 Sublect Amendment to PGE-1012," Fire Protection Plan," per DPMR 97-007, DCP 14," Remove Fire Detectors U134 and U135" Description of Channe. Test. Experiment Removal of the fire detectors was performed in 1997 and reported in PGE-1015-97, 'nnual . l Report of the Trojan Nuclear Plant," for the calendar year 1997. This report is made due to the changes incorporated into PGE-1012, Amendment 19.

The DCP removed fire detectors U134 and U135 and all associated conduit and cables from the 25 foot elevation of the Auxiliary Building. These detectors provided smoke detection for Room 141 (the Boron Injection Tank Room) and for Room 153 (the Centrifugal Charging Pump 'A' Room). PGE-1012, " Fire Protection Plan," Table 3.5-1, is revised (Amendment 19) to )

remove references to the fire detectors.

Summary of Safety Evaluation These changes do not increase the probability of occurrence of, or consequences from, an accident previously evaluated in the DSAR. The equipment originalfy contained in these rooms is not required to support safe storage ofirradiated fuel and is removed. As a result, the combustible loading of these rooms has been significantly reduced such that the subject detectors are not longer required. These changes do not affect plant equipment important to safety or the processes and procedures for responding to an equipment malfunction. These changes do not result in degradation in the reliability of structures, systems, or components credited in the j DSAR. Removal of fire detectors is addressed in Section 3.5.2 of PGE-1012, allowing  !

deactivation where the hazard (significant combustible loading) is removed.

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

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F 199810 CFR 50.59 Annual Report Safety Evaluation Number 97-028 Sublect Revision to PGE-1061," Trojan Nuclear Plant Decommissioning Plan" Description of Change. Test. Experiment The Decommissioning Plan is updated to reflect major radiologically contaminated components, structures, and/or systems removed. Revision 4 updates Table 2.2-5 to reflect major components removed in 1997. This is an annual update to Table 2.2-5.

Summary of Safety Evaluation This change is administrative in nature and is described in PGE-1061, Section 2.2.5.1, and can not increase the probability of occurrence of an accident previously evaluated in the DSAR.

These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and do not result in any degradation in the reliability of structures, systems, or components.

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

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199810 CFR 50.59 Annual Report Safety Evaluation Number 97-029 Subiect Revise PGE-8010, " Nuclear Quality Assurance (QA) Program," PGE-1061, " Trojan Nuclear Plant Decommissioning Plan," and the DSAR to Reflect Organization Changes Description of Chanee. Test. Experiment I The QA Program (Revision 21), DSAR (Revision 6), and Decommissioning Plan (Revision 4) are revised to reflect a change in the reporting relationship of the Purchasing Department. The l Purchasing Department was an offsite, corporate support organization and personnel supporting I Trojan are transferred to report to the General Manager, Plant Support and Technical Functions. l No changes to Purchasing Department responsibilities or functions are made.  !

Summary of Safety Evaluation These changes are administrative in nature and can not increase the probability ofoccurrence of an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and do not result in any degradation in the reliability of structures, systems, or components.

These changes do not afTect the margin of safety as defined in the Trojan Technical Specifications or Bases. It was determined that an unreviewed safety question does not exist for these administrative changes because 1) the probability of occurrence or consequences an accident or malfunction of equipment important to safety previously evaluated in the DSAR is not increased,2) the possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and 3) the margin of safety as defined in the basis for any Technical Specification is not reduced.

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199810 CFR 50.59 Annual Report l

Safety Evaluation Numbu 97-030 Subiect DPMR 97-002, DCP 3; and DPMR 97-027, DCP 1 and DCP 3; and Associated Document Changes Descrintion of Change. Test. Exneriment  ;

DPMR 97-002, DCP 3; and DPMR 97-027, DCPs I and 3, support an opening in the south wall l of the Control Building at the 93 foot elevation onto the Containment purge supply platform.

DPMR 97-C92. DC'P 3, modifies a spare Containment penetration and core boring holes in the Containment wall to allow routing of temporary elecrical services.

DPMR 97-027, DCP 1, provides building services and modifies the IIVAC System. .

l DPMR 97-027, DCP 3, removes Containment from the Protected Area boundary and provides an alternate access through the South wall of the Control Building. ]

Sections 3 and 4 of PGE-1012 are revised (Amendment 19) to delete the Containment wall as a

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three-hour fire rated boundary; incorporate a three-hour barrier deviation allowing access from the 93 foot elevation of the Control Building to Containment; and remove a portion of sprinkler system 'M.' ,

PGE-1017 (Revision 48) is revised to incorporate the changes to the Protected Area boundary.

The DSAR is revised (Revision 6) to identify the removai of a Control Building shear wall in i Figure 3.2-14.

Summary of Safety Evaluation These changes do not increase the probability of occurrence of an accident previously evaluated in the DS.AR. These changes do not affect the processes and procedures for responding to an equipment malfunction. These changes do not result in any degradation in the reliability of structures, systems, or components.

These changes do not affect the margin of safety as defined in the Trojan Technical  ;

Specifications or Bases. Therefore, these changes do not involve an unreviewed safety question j because, (1) there is no increase in the probability of occurrence or the consequences of an  !

I accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical 15

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I 199810 CFR 50.59 Annual Report i

Safety Evaluation Number 98-001 Subicet I

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DPMR 97-002, DCP 6, " Deactivate Component Cooling Water System (CCWS) 'A' Train l Component Air Coolers (CACs)"

Descriptio i of Change. Test. Experiment I The 'A' train CACs, associated CAC valves, and CCW pump cooling fans are deactivated and i isolated to support decommissioning efforts for component removal. A smaller pump was previously installed in the CCWS (under DPMR 94-008, DCP 3) for removal of decay heat from the Spent Fuel Pool. DSAR Figure 3.3-2 is revised and Section 3.3.3 descriptions of the CCWS ,

are revised to reflect the changes (Revision 6).

Summary of Safety Evaluation The CCWS no longer performs any safety related functions, but is classified as "important to the safe storage ofirradiated fuel." The smaller pump installed functions as the primary source for removal of decay heat from the Spent Fuel Pool and does not require a recirculation loop. These components are no longer required and, therefore, removal does not degrade the reliability of the CCWS for supplying cooling water to the Spent Fuel Pool heat exchangers or increase the probability oflosing CCWS cooling water flow. These changes do not increase the probability  !

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

These changes do not result in any degradation in the reliability of structures, systems, or l components. .

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

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l 199810 CFR 50.59 Annual Report Safety Evaluation Number 98-003 Subiect i DPMR 97-026, DCP 1 and DCP 2," Design and Installation of a Modular Spent Fuel Pool Cooling and Cleanup System Including the Operation of the Process Module of the Cleanup System" Description of Change. Test. Experiment A Modular Spent Fuel Pool Cooling and Cleanup System is installed. DCP 1 installed the Process Module portion of the System. DCP 2 installed the Cooling Module portion of the system. The existing Spent Fuel Cooling and Demineralizer System is not affected by this I installation. Evaluation of the adequacy of the system to perform the SFP cooling function and l removal of the existing system from service were not performed under this Safety Evaluation.

l PGE-1052 is revised (Amendment 7) to delete the requirement that the demineralizer and filter l portions of the SFP Cleanup System be within the Regulatory Guide 1.143 boundary since the failed fuel is removed (by the SFP Fuel Debris Removal Project) reducing the possibility that a breach of System pre.aure boundary integrity would result in significant radioactivity being released. PGE-1012, " Fire Protection Plan," (Amendment 20) and the DSAR (Revision 7) are revised to include a description of the System.

Summary of Safety Evaluation The existing Spent Fuel Cooling and Demineralizer System was not deactivated or removed by these DCPs. It was determined that an unreviewed safety question does not exist in the installation of the Modular Spent Fuel Pool Cooling and Cleanup System. The design of the System meets the existing requirements to limit inventory loss by syphoning and does not increase the probability of occurrence or consequences of an accident or malfunction of -

equipment important to safety previously evaluated in the DSAR. The possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created. The new System functions independent of any existing systems and is not quality or safety related.

The potential for a radiological release of SFP water from the process module piping is bounded by existing analyses. Both the existing and new Systems are Seismic Category II systems. The margin of safety as defined in the basis for any Technical Specification is not reduced. The bases for SFP level, temperature, boron concentration, and load restrictions are not affected.

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199810 CFR 50.59 Annual Report Safety Evaluation Number 98-004 Subieet DPMR 97-018, DCP 3," Isolate Instrument and Service Air to Containment" Description of Change. Test. Experiment This DPMR isolates instrument and service air supplies to Containment in the Turbine Building to support performance of decommissioning activities in the Main Steam Support Structure. The accumulators supplying air for the Main Steam isolation valves were previously deactivated and are removed by this DCP, eliminating the possibility for them to be pressurized. An altemate supply of air to Containment for tools, et cetera, is provided by a portable air compressor. The DSAR is revised (Revision 6) to remove the T-157 air accumulators from Table 3.1-3.

Summary of Safety Evaluation The accumulators supplying air for the Main Steam isolation valves were previously deactivated and are removed by this DCP. It was determined that an unreviewed safety question does not exist in the isolation ofinstrument and service air to Containment. The probability of occurrence or consequences an accident or malfunction of equipment important to safety previously evaluated in the DSAR is not increased. SFP integrity, inventory, makeup capability, and fuel handling are not affected. The possibility fo'r an accident or malfunction of a different type than any evaluated previously in the DSAR is not created. .The margin of safety as defined in the basis for any Technical Specification is not reduced. Pressurized air supply to Containment is not described in the Technical Specifications or Bases.

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i 199810 CFR 50.59 Annual Report )

l Safety Evaluation Number 98-005 l

l Subiect l DPMR 97-006, DCP 6, " Isolation of Chemical and Volume Control System (CVCS) Monitor l Tanks" Description of Change. Test. Experiment This DPMR deactivates the discharge flow path from the CVCS monitor tanks and pumps to the Discharge and Dilution Structure to allow decommissioning of the tanks. In addition, direct flow  ;

path from the Steam Generator Blowdown System to the plant discharge header is removed.  ;

l Summary of Safety Evaluation Isolation of the Steam Generator Blowdown System from the plant discharge header does not i impact the design or configuration of the SFP or its related make-up sources. These changes will  !

not increase the probability of occurrence of an accident previously evaluated in the DSAR. i These changes do not affect any plant equipment or the processes and procedures for responding I to an equipment malfunction. These changes do not result in any degradation in the reliability of i structures, systems, or components. The CVCS monitoring tanks and pumps are not discussed or described in the Technical Specifications. Specific flow paths from the Steam Generator l Blowdown System are not discussed or described in the Technical Specifications, therefore, i changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases.

It was determined that these changes do not involve an unreviewed safety question because,

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

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1 199810 CFR 50.59 Annual Report Safety Evaluation Number 98-006 i

Subleet l Revise the DSAR to Modify Seismic Monitoring Requirements l l

Descrintion of Chance. Test. Exocriment In consideration of the current plant conditions and the need to proceed with dismantling of equipment as an integral element of decommissioning, the seismic monitoring instrumentation

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requirements are modified. Sections 3.3 and 4.1.3 of the DSAR are revised (Revision 6) and Table 4.1-1 is deleted to incorporate the changes. Seismic monitoring instrumentation operability requirements and provisions for reporting instrumentation out of service to the NRC l are modified. In their place, requirements are added to 1) subject the instrumentation to routine  !

maintenance and testing,2) ensure that if an instrument is removed from service for greater than 30 days, alternate means are provided by which to record the data necessary for comparison with the design bases of facility features important to safety, and 3) ensure the instrumentation is in service during spent fuel cask loading operations.

i Summary of Safety Evaluation It was determined that an unreviewed safety question does not exist. Seismic monitoring j instrumentatio'n continues to meet the requirements of 10 CFR 100, Appendix A, and 10 CFR 50.72 and 50.73. The seismic moritoring instrumentation is not important to safety. l The capability to record data necessary from a seismic event for a prompt comparison with the design bases of facility features important to safety is maintained. Seismic monitoring l instrumentation does not affect the probability or magnitude of a seismic event and does not  !

l mitigate the consequences of a radioactive release, a fuel handling accident, or a loss of spent fuel decay heat removal capability. Therefore, the probability of occurrence or consequences an l accident or malfunction of equipment important to safety previously evaluated in the DSAR is not increased; and the possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created. Technical Specifications do not mention seismic monitoring instrumentation requirements so the margin of safety as defined in the basis i

for any Technical Specification is not reduced.

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( 199810 CFR 50.59 Annual Report l

l I Safety Evaluation Number 98-007 '

Subject DPMR 97-026, DCP 3, " Modular Spent Fuel Pool Cooling and Cleanup System Testing and Operation, and Radiation Detector Installation" Description of Chanee. Test. Exneriment i

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I This activity includes the installation of a radiation detector, and operation of the Modular Spent Fuel Pool Cooling and Cleanup System for performance testing and continued operation to ,

provide cooling and cleanup for the SFP. The DCP installs a radiation detector to the air cooler j enclosure drain line and includes calibration and performance testing. These activities do not j include deactivation of the existing SFP Cooling and Demineralizer System and other cooling l support systems. The DSAR is revised (Revision 7) to reflect the inclusion of the radiation  !

detector as a leakage monitor for the Modular Spent Fuel Pool Cooling and Cleanup System during system operation. The Technical Specification Bases (Revision 2), PGE-1012," Fire Protection Plan"(Amendment 20), and PGE-1063," Supplement to Applicant's Environmental l Report - Post Operating License Stage"(Revision 3), are revised to incorporate the Modular l Spent Fuel Pool Cooling and Cleanup System. j Summarv of Safety Evaluation These changes do not increase the probability of occwrence of an accident previously evaluated in the DSAR. These changes do not affect the processes and procedures for responding to an equipment malfunction. These changes do not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases.

Therefore, these changes do not involve an unreviewed safety question because, (1) there is no l increase in the probability of occurrence or the consequences of an accident or malfunction of l i

equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and l (3) the margin of safety as defined in the basis for any technical specifications is not reduced. I l

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l 199810 CFR 50.59 Annual Report I

i Safety Evaluation Number 98-008 Subiect DPMR 98-001, DCP 1 and DCP 2," Revise Credited Makeup Water Sources to the Spent Fuel Pool and Remove Service Water Pump" .

l Description of Change. Test. Experiment The Demineralized Water and Primary Makeup Water Systems are deleted from licensing documents as credited SFP makeup sources. Domestic (potable) water and portable pumps taking suction from the Columbia River are added as DSAR designated SFP makeup sources.

The 'A' Service Water pump (P-108A) is removed from the system indefinitely. The DSAR is revised (Revision 7) to incorporate the changes and delete references to specific system components and specific flow paths to the SFP. PGE-1012," Fire Protection Plan,"is revised (Amendment 20) to indicated the change in designated flow path to the SFP.

Summarv of Safety Evaluation Changing the "Important to the Safe Storage ofIrradiated Fuel" designated makeup sources and leaving the Service Water pump removed from the System indefinitely do not increase the probability of occurrence of an accident previously evaluated in the DSAR. The Service Water System is no longer important to safetf. The changes do not create the possibility of an accideht i

of a different type than any Weady evaluated in the DSAR since the newly designated makeup sources are similar to the other, existing makeup sources. These changes do not atTect the processes and procedures for responding to an equipment malfunction. These changes do not I result in any degradation in the reliability of structures, systems, or components. Multiple and . I diverse means of supplying water to the SFP are maintained. An installed spare pump (P-108C) {

is aligned to supply 'A' train Service Wa.er in place of the 'A' pump. The cuirent loads on the  !

Service Water System are easily supplied by one pump. There is no requirement to maintain the additional pump. Also, normal Service Wata meds are adequately supplied by one of the two Cooling Water pumps in place. No change to the Defueled Technical Specifications is required '

as requirements associated with SFP level, boron concentration, temperature, and load restrictions remain unchanged, therefore, changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases.

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

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199810 CFR 50.59 Annual Report l

Safety Evaluation Number 98-009 l

1 Subleet DPMR 97-006, DCP 7, " Dirty Radioactive Waste System (DRWS) Modification" l Descrintion of Chanee. Test. Exneriment

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l A portion of the Containment sump discharge drain piping to the dirty radioactive waste drain tank is deactivated, along with associated components and valves. In its place a hose is routed from Containment to a floor drain outside Containment in the pipe facade to serve as the i Containment sump drain.

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l Summary of Safety Evaluation These changes do not increase the prooability of occurrence of an accident previously evaluated in the DSAR. Deactivation of portions of the DRWS and the use of hoses in lieu of piping do i not affect any of the evaluated accidents in the DSAR. The DRWS does not perform any safety functions. These changes do not affect any plant equipment or the processes and precedures for responding to an equipment malfunction. The changes do not significantly change the way that the Containment sumps are operated; waste water from the sumps will continue to be pumped into the DRWS. These changes do not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases.

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

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l 199810 CFR 50.59 Annual Report i

Safety Evaluation Number 98-010 '

Subiect Replace the Original SFP Cooling System with the Modular Spent Fuel Pool Cooling System per DPMR 97-026 and Associated Licensing Document Changes Description of Change. Test. Experiment The original SFP Cooling System is replaced by a Modular SFP Cooling System. This allows  ;

deactivation of various support systems, such as the CCWS, and portions of the SWS. The new Modular Cooling System is designated as the primary method of SFP cooling. A radiation detector is installed to monitor for potential leaks in the System air coolers (see SE 98-007). j Revision is made to the DSAR (Revision 7), PGE-1012," Fire Protection Plan" (Amendment 20),

PGE-1063," Supplement to Applicant's Environmental Report - Post Operating License Stage" ,

(Revision 3), and the Technical Specification Bases (Revision 2), to incorporate the new l Modular SFP Cooling System as the primary mode of SFP cooling.

Summary of Safety Evaluation These changes do not increase the probability of occurrence of an accident previously evaluated ,

in the DSAR. The cooling capability for all design basis conditions is maintained. Locating the ]

siphontreaker in a more conservative location actually lessensT3FP inventory loss in the event of 1 a Cooling System piping breach. These changes do not affect the processes and procedures for responding to an equipment malfunction. These changes do not result in any degradation in the reliability of structures, systems, or components. Neither the new System or the System that was removed perfonn any safety related functions. However, the new System retains the designation of"Important to the Safe Storage ofIrradiation Fuel." The Modular SFP Cooling System '

limited to the cooling functions associated with the SFP and is physically separated fron, . of

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the remaining major decommissioning activities to take place in the Containment, Fuel, and l

Auxiliary Building, thereby reducing the risk of component damage by ongoing 1 decommissioning work. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases. The design, installation, and testing of the new System were done in accordance with the Technical Specifications.

Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident ,

or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

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h 199810 CFR 50.59 Annual Report Safety Evaluation Number 98-011 Sublect Revise PGE-1012," Fire Protection Plan," per DPMR 98-013, DCP 1 Description of Chanee. Test. Experiment This Safety Evaluation is included in the report for the revision to PGE-1012 (Ameni.nent 20).

Work activities for DPMR 98-013, DCP 1, " Fire Suppression Backout Plan for the Auxiliary and Fuel Buildings," were not completed in 1998. The DCP will remove seven deactivated  !

suppression systems from the Auxiliary and Fuel Buildings as part of the overall backout plan.

These systems were previously deactivated and abandoned in place. Sections 3 and 4 of PGE-1012 are revised to remove deluge valves, pressure switches, trim components, suppression piping, and other components. These suppression systems are listed and described as deactivated ,

systems. The isolation valves for these systems are currently on the system boundary list and are j deleted based on the installation of blind fianges, caps, or plugs, at the valve locations.

Summary of Safetv Evaluation These changes are administrative in nature. These changes do not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipthent malfunction.

The systems are designated as deactivated and no longer provide any fire protection ftmetion.

These changes are not associated with plant equipment design, operation, or maintenance and do not result in any degradation in the reliability of structures, systems, or components. The removal of previously deactivated suppression systems is within the scope of the current license requirements to develop and maintain a Fire Protection Plan for the facility, therefore, changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases.

These changes do not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or c.; r~~"-aras of an accident or malfunction of equipment important to safety previously evaluated ni une DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

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199810 CFR 50.59 Annual Report SafetyEvaluation Number 98-012 Subiect DPMR 98-006, DCP 4," Liquid Radioactive Waste System and Discharge Header Monitoring Instrumentation Modification" Descrintion of Change. Test. Experiment The Liquid Radioactive Waste System is modified. The Liquid Radioactive Waste Discharge Header instrumentation is modified and the rate indicator moved to the 45 foot elevation of the Auxiliary Building. Equipment associated with the Clean Waste Receiver Tanks is deactivated. l Temporary cable and a programmable logic controller for liquid radioactive waste are installed.

DSAR, Sections 5.3 and 5.5, are revised to incorporate the changes (Revision 7).

Summary of Safety Evaluation These changes do not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect the processes and procedures for responding to an  ;

equipment malfunction. These changes do not result in any degradation in the reliability of i structures, systems, or components. The Liquid Radioactive Waste System does not perform any safety related functions. The capacity, method of treatment, and means for monitoring liquid radioactive waste are not changed. These changes do not affect the margin of safety as d6fimed in the Trojan Technical Specifications or Bases.

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

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r 199810 CFR 50.59 Annual Report Safety Evaluation Number 98-013 Subiect Corrective Action Request 98-012, " Environmental Evaluation for Digging Test Pits" Description of Change. Test. Experiment An environmental evaluation for test pits dug in the barge fill area for preparation of the non-radiological decommissioning cost estimate was performed. During initial licensing of the Trojan plant, an area adjacent to the barge slip was found to contain native American artifacts and was determined to be an archeological area. Agreements were reached regarding the preservation of this aiea as specified in the Environmental Statement dated August 1973, Section 7.l(1). This Enviromnental Evaluation was performed to ensure compliance with those agreements.

Summary of Safety Evaluation These changes do not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and do not result in any degradation in the reliability of structures, systems, or componedts. The barge fill area is remote from the

• Radiologically Controlled Area and does not interface with SFP equipment or boundary. The test pits dug in the archeological area were relatively small and refilled with excavated material.

Adjacent waters and aquatic life were not impacted. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases.

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

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199810 CFR 50.59 Annual Report Safety Evaluation Number 98-014 Subiect Revise the DSAR to Incorporate Service Water System (SWS) Changes D_gseription of Chanee. Test. Experiment Administrative changes to the DSAR, Section 3.3.4.2 and Figure 3.3-3, are made (Revision 6) to expand the description of the SWS for clarification of prior modifications to the System. The changes are made with regard to DPMR 95-005, DCP 1, and DPMR 96-013, DCP 2. Other, miscellaneous clarifications are also included.

Under DPMR 95-005, DCP 1, the Fish Rearing Piping and pumps were modified so river water could be supplied to the SWS via the Fish Rearing pumps. The pumps were renamed " Cooling Water pumps" because the modification provided a flowpath for cooling water (i.e., river water) to the SWS.

Under DPMR 96-013, DCP 2, a hose connection was installed on the 'A' train SWS makeup piping to the SFP. Included were minor modifications to the CCW makeup pump piping which provides easy connections and installation of a bose between the CCW makeup pump discharge piping and the 'A' train SWS makeup to the SFP piping. *Through this hose connection, SFP makeup flow can be provided.

Summary of Safety Evaluation These changes to the DSAR are administrative in nature and do not increase the probability of occurrence of an accident previously evaluated in the DSAR. Modifications to the SWS described were made and reported separately. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes do not result in any degradation in the reliability of structures, systems, or components. No change to the Defueled Technical Specifications is required as these changes are administrative and do not affect or degrade the plant's ability to maintain the required SFP boron concentration, temperature or water level, therefore, changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases.

These changes do not involve an unreviewed safety question because, (1) there is no increase in the probability of occmrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR,(2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and I

(3) the margin of safety as defined in the basis for any technical specifications is not reduced.

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199810 CFR 50.59 Annual Report I Safety Evaluation Number 98-015 Subiect Revise the DSAR, PGE-1012," Fire Protection Plan," and PGE-1063, " Supplement to Applicant's Environmental Report - Post Operating License Stage," for Modifications Performed Unde DPMR 97-007, DCP 19," Service Water Booster Pump Deactivation" l Description of Change. Test. Experiment A complete turnover of DPMR 97-007, DCP 19, was not performed in 1998. This Safety Evaluation is reported for changes to the licensing documents associated with the DPMR. Under DPMR 97-007, DCP 19. The 'B' train Service Water booster pumps were deactivated and isolated, and the portion of the 'A' train SWS downstream of(and including) strainer F-101 A was deactivated, isolated and removed, and miscellaneous minor changes to the SWS were performed.

DSAR, Section 3.3.4 and Figures 3.3-2 and 5.3-1, are revised (Revision 7) to delete 'A' train SWS, associated piping, and valves. " Service Water" is designated as " Flush Water" for the  !

PERM 9 flush water description. l PGE-1012, Sections 4.5 and 4.8, are revised (Amendment 20) to derete reference to SWS strainers and selected room coolers. Reference to the strainers is revised to refer to the strainer i pit.

PGE-1063, Section 4.5, is revised (Revision 3) to delete reference to selected room coolers.

Summary of Safety Evaluation These changes are administrative in nature and do not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes do not result in any degradation in the reliability of structures, systems, or components. The changes do not affect equipment considered important to safety. These changes do not effect the margin of safety as defined in the Trojan Technical Specifications or Bases.

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

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199810 CFR 50.59 Annual Report Safety Evaluation Number 98-016 Sub_iect DPMR 98-017, DCP 1," Fire Suppression System Removal - Water Spray Systems 23 through 27" Description of Chanee. Test. Experiment Water Spray Systems 23,24,25, and 27 are deactivated and removed. These suppression system requirements are no longer applicable to Trojan. PGE-1012 is revised to incorporate the changes (Amendment 20).

Summary of Safety Evaluation These changes do not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect the processes and procedures for responding to an equipment malfunction. These changes do not result in any degradation in the reliability of structures, systems, or components. The suppression systems are remote from the SFP area and the changes to not impact the safe storage of spent fuel. The suppression systems were installed to provide Appendix R train separation for the Component Cooling Water and Service Water, booster pumps. The booster pumps that the suppression systems supported will be deactivated and removed by DPMR 97-007, DCP 15. Appendix R requirements are no longer applicable to Trojan. The area is covered by the high voltage smoke detection system, and has fire hose stations and portable fire extinguishers in place for manual suppression should a fire start in this area. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases.

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

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199810 CFR 50.59 Annual Report Safety Evaluation Number 98-017 Sublect DPMR 98-006, DCP 1," Radioactive Waste System Consolidation, Phase 1" Description of Chanee. Test. Experiment This DPMR modifies the Liquid Radioactive Waste (LRW) Systems to consolidate System function to the 45 foot elevation and below of the Auxiliary and Fuel Buildings. The process flowpath is relocated. Discharge from the clean and dirty radioactive waste pumps are rerouted to one of the skid filters (influent filter) and then to one receiving tank. Process piping and filters are installed, with connections for a demineralizer. Non-required portions of the existing LRW System are deactivated. Liquid radioactive waste may be processed from the receiving tank through the second filter (effluent)(and portable demineralizer, ifinstalled in the future) to the other discharge tank, or may be recirculated, sampled, and discharged directly.

DSAR, Sections 1.2,3.3,5.3,5.5, Figures 3.3-1,5.3-1, and 5.4-1 are revised (Revision 7) to reflect the modifications. Figures 5.3-2 and 5.3-3 are deleted.

PGE-1052, " Quality-Related List Classification Criteria for the Trojan Nuclear Plant,"

Section 4.8 is revised (Amendment 7) to incorporated the changes and Figures 4.8.2-1 througfi 4.8.2-20 are deleted.

PGE-1021, "Offsite Dose Calculation Manual," Figure 2-1, is revised (Amendment 15) to correctly reflect the operation of the Liquid Radioactive Waste treatment System.

Summary of Safety Eval'uation These changes do not increase the probability of occurrence of an accident previously evaluated in the DSAR. The consolidated system is operated in the same manner, therefore, no new accident scenarios are created. These changes do not affect any processes and procedures for responding to an equipment malfunction. These changes do not result in any degradation in the reliability of structures, systems, or components. The amount of process piping in service is significantly reduced by the modification, reducing the overall risk of system damage due to ongoing decommissioning work. Appropriate piping modifications are made to allow storage, processing, tank recirculation, and discharge ofliquid radioactive waste while maintaining current processing and discharge requirements. This modification does not involve any equipment classified as important to safety. No change to the Defueled Technical Specifications is required as the system changes do not affect the Radioactive Effluent Controls Program, therefore, changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases.

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199810 CFR 50.59 Annual Report These changes do not involve an unreviewed safety question because,(1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

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i i 199810 CFR 50.59 Annual Report Safety Evaluation Number 98-018 i

Subiect Replacement of the Original Spent Fuel Pool Demineralizer System with the New Modular Spent Fuel Pool Cleanup System and Associated Document Changes Description of Change. Test. Experiment The new Modular SFP Cleanup System is designated as the primary mode of spent fuel pool l purification. The System was installed per DPMR 97-026, DCP 1 (reported with Safety l Evaluation 98-003 in this report). This change removes the description and information associated with the former system from the DSAR and PGE-1052.

DSAR, Sections 3.3,4.0,4.1,4.3, and Figure 3.3-4, are revised (Revision 7) to incorporate the l

modification.

PGE-1052," Quality-Related List Classification Criteria for the Trojan Nuclear Plant," )

Section 4.8 and Figure 4.8.2-11 are revised (Amendment 7) to incorporate the modification. I Summarv of Safety Evaluation These i:hanges are administrative in nature and do not increase'the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect the processes and procedures for responding to an equipment malfunction. These changes do not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases.

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

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199810 CFR 50.59 Annual Report Safety Evaluation Number 98-019 Subject DPMR 98-017, DCP 2, " Fire Suppression System Removal - Sprinkler System BD" Description of Change. Test. Exneriment Fire Suppression System, Sprinkler System BD is deactivated and removed. Appendix R requirements for this suppression system are no longer applicable to Trojan. PGE-1012 is revised to incorporate the changes (Amendment 20).

Summary of Safety Evaluation These changes do not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not afTect the processes and procedures for responding to an equipment malfunction. Thee changes do not result in any degradation in the reliability of structures, systems, c, components. These changes do not involve equipment classified as important to safety. The suppression system is remote from the SFP area and the changes do not impact fuel headling or the safe storage of spent fuel. The suppression system was installed to help meet appendix R train separation, safe shutdown, requirements. Appendix R requirements are no :onger applicable to Trojan. The area is covered by the high voltage smoke detection syr.em, and has* fire hose stations and portable fire extinguishers in place for manual suppression r'aould a fire start in this area. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases.

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

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199810 CFR 50.59 Annual Report Safety Evaluation Number 98-021 Subiect DPMR 98-006, DCP 5," Remove Inputs from Clean and Auxiliary Building Radioactive Waste Drains" Descrintion of Change. Test. Exneriment DPMR 98-006, DCP 5 cuts drain lines to the Auxiliary Building Radioactive waste System and to the Clean Radioactive waste System and routes them to floor drains. This work is being performed to allow consolidation of the Radioactive Waste System in preparation for decommissioning and decontamination of various radioactive waste systems, including embedded piping. With the rerouting of the drains to floor drains, the discharges from the various systems are now directed to the Dirty Radioactive Waste (which became the Liquid Radioactive waste Processing System).

PGE-1052," Quality-Related List Classification Criteria for the Trojan Nuclear Plant,"is revised (Amendment 7) to incorporate descriptions of destinations of drain pipes and sample sink discharges.

Summary of Safety Evaluation *

'Ihese changes do not increase the probability of occurrence of an accident previously evaluated in the DSAR. Radioactive waste processing systems perform ng safety functions and do not impact the safe storage ofirradiated fuel. The specific route into the Radioactive Waste Processing System and the specific holding tank used to begin processing does not affect the processing method, capabilities, or output from the System. These changes do not affect the processes and procedures for responding to an equipment malfunction. These changes do not result in any degradation in the reliability of structures, systems, or components. With the plant in a permanently defueled condition and completion of cleanup of debris from the Spent Fuel Pool, the need for clean radioactive waste, i.e., high activity / low particulate Radioactive Waste System is no longer required. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases.

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

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l 199810 CFR 50.59 Annual Report l

Safety Evaluatien Number 98-023 Subject Revise PGE-1060," Permanently Defueled Emergency Plan (PDEP)," to Incorporate Minor Editorial Changes and Remove Copies of the Letters of Agreement from Appendix A (Revision 6)

Description of Change. Test. Experiment _

l Copies of Letters Of Agreement (LOAs) are deleted from the PDEP, Appendix A. Minor

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l editorial changes are made to Sections 3.1,3.5,8.4.1, and Table 4-2.

Summary of Safety Evaluation 1 i

i The PDEP describes emergency response measures that require the coordination or cooperation 1 of offsite agencies and organizations. The basis for these measures are LOAs established with l

l the appropriate agencies and organizations. For referencing convenience, copies of the LOAs l were placed in an appendix to the Plan and were not intended to be part of the Plan description.

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l The changes do not affect any aspect of the Emergency Preparedness Program or how it is i implemented. These changes are administrative in nature and do not ir.aea:.e the probability of occurrence of an accident previously e' valuated in the DSAR. These changes do not affect any' plant equipment or the processes and procedures for responding to an equipment malfunction. 1 Removing the LOAs from Appendix A does not change the emergency response measures  !

described in the PDEP or the provisions established by the LOAs for implementing those measures. These changes are not associated with plant equipmem design, operation, or )

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

Specifications or Bases.

Therefore, these changes do not involve an unreviewed safety question because, (1) there is no  ;

increase in the probability of occurrence or the consequences of an accident or malfunction of l equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and  !

I (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

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199810 CFR 50.59 Annual Report l

l Safety Evaluation Number 98-024 Subiect Corrections to the List of Procedures in PGE-1021, "Offsite Dose Calculation Manual" Description of Change. Test. Experiment The list of references in PGE-1021, Process Control Program, Section 6.5, is updated to reflect procedures currently in use, delete those no longer used, and correct procedure numbers and names (Amendment 15).

Summary of Safety Evaluation These changes are administrative in nature and do not increase the probability of occurrence of -

an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and do not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases.

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

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l 199810 CFR 50.59 Annual Report Safety Evaluation Number 98-025 l

Subiect  !

Delete PGE-1030, " Environmental Monitoring Plan," as a License Implementation Document l

Description of Change. Test. Experiment l The Non-Radiological Environmental Monitoring Program is revised to eliminate the l Environmental Monitoring Plan. PGE-1030 no longer satisfies any regulatory requirements and is removed as a licensing basis document.

Summary of Safety Evaluation This change is administrative in nature and does not increase the probability of occurrence of an accident previously evaluated in the DSAR. PGE-1030 is not necessary to implement the Environmental Protection Plan (EPP), Operating License, NPF-1, Appendix B. The change does

. not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. The change is not associated with plant equipment design, operation, or maintenance and does not result in any degradation in the reliability of structures, systems, or components. Due to the non-operational condition of the plant, environmental concerns are significantly reduced. PGE requested and received approval from the Oregon Department of ,

l Fish anti Wildlife to eliminate this Plan. All existing effluents are monitored by NPDES permit requirements administered by the Oregon Department of Environmental Quality. The change

. does not affect the margin of safety as defined in the Trojan Technical Specifications or Bases.

Therefore, the change does not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of l equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident i or malfunction of a different type than any evaluated previously in the DSAR is not created, and l

(3) the margin of safety as defined in the basis for any technical specifications is not reduced.

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199810 CFR 50.59 Annual Report Safety Evaluation Number 98-026 Subiect Revise the DSAR per DPMR 97-012, DCP 3 Description of Change. Test. Experiment DSAR, Figure 3.2-1, is revised (Revision 7) to incorporate an embedded impact limiter in the Fuel Building 45 foot elevation crane bay slab. DSAR changes only are included with this report. Field work associated with DPMR 97-012, DCP 3, was not completed in 1998.

DPMR 97-012, DCP 3, will modify the Fuel Building crane bay floor to install an impact limiter.

The 45 foot elevation of the Fuel Building, the crane bay floor, will be partially excavated and replaced with a reinforced concrete slab to house the embedded impact limiter, IL-2. This limiter supports ISFSI fuel basket transfers baween the Transfer Cask and the Storage Cask.

Summarv of Safety Evaluation This change is administrative in nature and does not increase the probability of occurrence of an accident previously evaluated in the DSAR. This change does not affect any plant equipment or the processes and procedures for responding to an equipment rnalfunction. This change is not associated with plant equipment design, operation, or maintenance and does hot result in ar.y degradation in the reliability of structures, systems, or components. This change does not affect the margin of safety as defined in the Trojan Technical Specifications or Bases.

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

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199810 CFR 50.59 Annual Report Safety Evaluation Number 98-027 Subiect Revision 22 to PGE-8010, " Nuclear Quality Assurance (QA) Program" Descrintion of Change. Test. Exneriment The QA Program, Section 1, is revised to reflect that the ISFSI Safety Review Committee (ISRC) review functions are located in the ISFSI Safety Analysis Report instead of the ISFSI Technical Specifications.

Summary of Safety Evaluation Administratively relocating ISRC functions does not reduce QA Program commitments previously accepted by the NRC. These changes do not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the p.ocesses and procedures for responding to an equipment mahhnetion. These changes are not associated with plant equipment design, operation, or maintenance and do not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases.

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

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199810 CFR 50.59 Annual Report Safety Evaluation Number 98-029 Subiect Amendment 20 to PGE-1012," Fire Protection Plan," per DPMR 98-007, DCP 5 Description of Channe. Test. Experiment PGE-1012, Table 3.5-1,is revised to delete the smoke detector system at the 5 foot and 25 foot elevations of the Auxiliary Building. Section 4.1.5.1 is revised to adjust the highest combustible loading range on the 61 foot elevation corridor to reflect removal of combustible material.

Modifications to the plant were not completed in 1998. This Safety Evaluation is reported for changes to PGE-1012 only.

DPMR 98-007, DCP 5, removes all fire detectors and associated conduit and cables from the 5 foot and 25 foot elevation of the Auxiliary Building. Most of the equipment originally contained in these areas was not required to support safe storage ofirradiated fuel and was removed. As a result, the combustible loading of these areas has been significantly reduced such that the subject detectors are no longer required.

Summary of Safety Evaluation These changes are administrative in natdre and do not increase the probability of occurrence of -

an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and do not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases.

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

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i 199810 CFR 50.59 Annual Report Safety Evaluation Number 98-030 Subiect DPMR 98-012, DCP 3, " Deactivate and Remove the Spent Fuel Pool Exhaust System Post Charcoa! Filter HEPA Filters" Description of Change. Test. Experiment DPMR 98-012, DCP 3, removes the SFP Exhaust System post charcoal IIEPA filters located on the 93 foot and 105 foot elevations of the Auxiliary Building. The IIEPA filters were needed to capture any charcoal particles and are not required due to removal of the charcoal filters upstream. DSAR, Figure 5.2-6,is revised (Revision 7) to indicate removal of the filters.

Summary of Safety Evaluation These changes do not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. The IIEPA filters do not interface with any equipment classified as important to safety and, therefore, the changes do not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases.

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

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! 199810 CFR 50.59 Annual Report i-Safety Evaluation Number 98-031 Suhltd DPMR 98-006, DCP 2," Deactivate Various Radioactive Waste Equipment" D_tscription of Change. Test. Experiment DPMR 98-006, DCP 2, deactivates various radioactive waste equipment including the Clean Waste Receiver Tanks (CWRTs) with associated pumps and piping, the Spent Resin Storage Tank (SRST) with associated pumps and piping, and the primary sample sink.

DSAR, Sections 5.3, 5.4, and Figure 5.3-1, are revised (Revision 7) to incorporate the changes.

Figure 5.4-1 is deleted.

PGE-1012, " Fire Protection Plan," Section 5.8.3 is deleted (Amendment 20) to reflect deactivation of the SRST and associate rl pumps and piping.

PGE-1021, "Offsite Dose Calculation Manual," Figure 2-1, is revised (Revision 15) to reflect deactivation of the CWRT and associated pumps and piping.

Sumniary of Safety Evaluation

• These changes do not increase the probability of occurrence of an accident previously evaluated in the DSAR. The quantity of radioactive liquids generated has diminished significantly during the course of decommissioning at Trojan. All former sources ofliquid to the CWRTs are either rerouted to another tank in the liquid radioactive waste system, or no longer in service. There are no more sources of resin to the SRST, as all installed plant demineralizers are deactivated and/or  ;

removed. Resin associated with demineralizers used for decommissioning support (e.g.,

Modular SFP Cooling and Cleanup System or Gap Flush System) will be processed directly to a container for burial and do not require storage on the SRST. The primary sample sink is no longer required to obtain necessary samples. The cleanup portion of the Modular SFP Cooling System is in service and connections are provided to obtain SFP water samples. Sampling of radioactive _ waste tanks is performed locally. These changes do not affect the processes and procedures for responding to an equipment malfunction. These changes do not result in any degradation in the reliability of structures, systems, or components. Reduction in liquid Radioactive Waste System storage capacity by removal of the CWRTs has no adverse impact on the ability to collect, process, and discharge water per plant discharge requirements. Radioactive waste processing systems have no safety functions and do not impact the safe storage ofirradiate fuel or involve any equipment classified as important to safety. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases.

l Therefore, these changes do not involve an unreviewed safety question because, (1) there is no 44 l

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199810 CFR 50.59 Annual Report 1

merease m the probability ofoccurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident or malfunction of a different type than any evaluated previously in the DSAR is not created, and (3) the margin of safety as defined in the basis for any technical specifications is not reduced.

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199810 CFR 50.59 Annual Report i 1

Safety Evaluation Number 98-032 l

l Subiect ,

Revision 51 to PGE-1017," Permanently Defueled Security Plan (Defueled Condition)"

Dsseription of Change. Test. Experiment

! PGE-1017 is revised to reflect that the Security Alarm Station is moved from the Control Room to the Access Control Facility (ACF) Access Booth.

DPMR 98-003, DCP 2," Consolidation of Alarm Stations in the ACF," installs the necessary equipment, conduits and electrical connections to support the relocation of the alarm station to the ACF booth. Field work for DPMR 98-003, DCP 2, was completed in 1998.

i Summary of Safety Evaluation l l These changes do not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect the processes and procedures for responding to an l equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and do not result in any degradation in the reliability of structures, systems, or components. Relocation of the security alarm station does not change access requirements or alarm monitori6g capabilities. These changes do not affect the margin 6f safety as defined in the Trojan Technical Specifications or Bases.

l Therefore, these changes do not involve an unreviewed safety question because, (1) there is no increase in the probability of occurrence or the consequences of an accident or malfunction of l equipment important to safety previously evaluated in the DSAR, (2) a possibility for an accident l or malfunction of a different type than any evaluated previously in the DSAR is not created, and  !

(3) the margin of safety as defined in the basis for any technical specifications is not reduced. l 1

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I 199810 CFR 50.59 Annual Report Safety Evaluation Number 98-034 l

Subject

Revise PGE-1060," Permanently Defueled Emergency Plan," and PGE-1021,"Offsite Dose

! Calculation Manual," per DPMR 97-007, DCP 20 l

! Description of Chanee. Test. Experiment DPMR 97-006, DCP 20, Deactivates the Vent Collection Header Syst::m, including the Vent Collection Header exhaust fan and Process and Effluent Radiation Monitor (PERM) 5. Field work under DPMR 97-007, DCP 20, and associated changes to the DSAR were not completed in ,

1998. Completed licensing document changes are reported only. j PGE-1060, Section 8.4.2, is revised (Revision 7) to delete the description of Vent Collection Header System operation.

PGE-1021, Figure 3-1, is revised (Amendment 17) to delete Vent Collection Header input to the Ventilation Exhaust Treatment System.

l Summarv of Safety Evaluation These changes are administrative in nature hnd do not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are not associated with plant equipment design, operation, or maintenance and do not result in any degradation in the reliability of structures, systems, or components. These changes do not affect the margin of safety as defined in the Trojan Technical Specifications or Bases.

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

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l l 199810 CFR 50.59 Annual Report l

Safety Evaluation Number 98-037 Subiect Amendment 16 to PGE-1021,"Offsite Dose Calculation Manual" Descrintion of Change. Test. Exneriment PGE-1021, Section 6.0, " Trojan Process Control Program for Solid Radioactive Waste," is revised to reflect current industry terminology, clarify intent, correct references, delete procedures no longer applicable, and delete listing of vendor procedures. Section 6.5 is deleted since the referenced computer programs are no longer used. Corrections to sampling locations are made to Figure 5-1 and Table .5-1.

Summary of Safety Evaluation These changes are administrative in nature and do not increase the probability of occurrence of an accident previously evaluated in the DSAR. These changes do not affect any plant equipment or the processes and procedures for responding to an equipment malfunction. These changes are net associated with plant equipment design, operation, or maintenance and do not result in any degradation in the reliability of structures, systems, or components. The Process Control Program is required to comply with various regulations, including 10 CFR 20,10 CFR 61, 10 CFR 71, state regulations, and burial ground requir6ments. The proposed changes update the Process Control Program to use current terminology used by the industry and alleviate the need to update the PCP whenever a vendor renumbers or changes their procedures. These changes do not affect the margin of safety as dermed in the Trojan Tecimical Specifications or Bases.

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

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