ML20210M590
| ML20210M590 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 08/05/1999 |
| From: | Quennoz S PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20210M593 | List: |
| References | |
| TAC-MA5016, VPN-054-99, NUDOCS 9908100125 | |
| Download: ML20210M590 (16) | |
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( Portland General Electric Company Tmjan Nuclear Plant 71760 Columbia River iluy Rainier, OR 97048
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August 5,1999 VPN-054-99 Trojan Nuclear Plant Docket 50-344 License NPF-1 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
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Re-Submittal of PGE-1078, l j
" Trojan Nuclear Plant License Termination Plan;" and Transmittal
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of License Change Application (LCA) 247, Revision 1 (TAC NO. MA5016) I In response to a Nuclear Regulatory Commission (NRC) Staff request dated April 29,1999, and in accordance with 10 CFR 50.82(a)(9), Attachment III to this letter, together with the Trojan Nuclear Plant License Termination Plan submitted by Portland General Electric Company (PGE) letter VPN-007-99 dated March 10,1999, constitutes PGE's re-submittal of PGE-1078, " Trojan Nuclear Plant License Termination Plan." This letter also transmits (Attachments I and II)
Revision 1 to LCA 247, which requests amendment of Facility Operating (Possession Only)
License No. NPF-1. LCA 247, Revision 1, proposes to add a license condition denoting NRC approval of PGE-1078," Trojan Nuclear Plant License Termination Plan," as supplemented by Attachment III to this letter. LCA 247, Revision 1, is submitted in accordance with 10 CFR 50.82(a)(10), which requires NRC approval of the License Termination Plan by license I amendment.
Background
By PGE letter VPN-007-99, " License Change Application (LCA) 247 - License Amendment For Approval of PGE-1078, ' Trojan Nuclear Plant License Termination Plan'," dated March 10,1999, PGE submitted to the NRC the Trojan Nuclear Plant License Termination Plan.
In a letter from L. H. Thonus to S. M. Quennoz, " Completeness Review of Trojan License
' Termination Plan (TAC NO. MA5016)," dated April 29,1999, the NRC requested that the Dh Trojan Nuclear Plant License Termination Plan be resubmitted with additional detail in Section 5," Final Survey Plan."
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VPN-054-99 August 5,1999 Page 2 of 5 -
In subsequent telephone communications between PGE and NRC staff, the specific detail items :
_ requested to be provided as part of or as supplementary information to the Final Survey Plan section of the License Termination Plan were clarified. The additional detail, as clarified, is intended to provide identification and characterization of survey units, and specifically includes area maps depicting survey units and a listing of survey unit size, classification, and number of samples per survey unit. The NRC also requested wording in the Final Survey Plan section regarding " screening Derived Concentration Guideline Levels (DCGLs)" to clarify that the screening DCOLs are intended to be used as the principle criteria for releasing the site. With the exception of the area maps, this additional detail is included as a part of the Final Survey Plan j section of the License Termination Plan provided in Attachment IIL The area maps depicting J survey units are provided in Attachment IV as supplementary information. The DandD modeling runs used to develop the screening DCGLs are provided as supplementary infom1ation in Attachment V. Attachments III, IV, and V to this letter provide the additional level of detail requested in the NRC's April 29,1999, letter as clarified in subsequent telephone communications and cited above.
During the aforementioned telephone communications, the NRC also requested that additional criteria be added to the license condition proposed in LCA 247 to control changes to the Final Survey Plan portion of the License Termination Plan. Attachments I and II to this letter provide the proposed additional criteria.
1 PGE-1078 Section 5," Final Survey Plan," Methodology j l
- Section 5, " Final Survey Plan," incorporates additional level of detail related to survey unit l descriptions, simplifies and clarifies the use of and methodology used to develop screening !
DCGLs, and provides the basis for the determination of minimum sample frequency. The screening DCOLs are based on NUREG-5512 dose assessment scenarios and are calculated using the NRC's DandD software with the NUREG-1549 default scenario parameters. No site-specific model or parameter changes are applied. To assist in the NRC's review of the Final ;
Survey Plan Section, the DandD modeling runs used to develop the screening DCGLs are !
provided as Attachment V to this letter, i
The Trojan Nuclear Plant Final Survey Plan is designed for practical field application of the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) process, and in I many instances exceeds the MARSSIM and related draft regulatory guidance to ensure the quality and comprehensiveness of the final survey process at the Trojan Nuclear Plant site. For example, with the possible exception of certain plant systems and/or embedded piping as provided in Final Survey Plan Section 5.4.3.1, Footnote 4, the Trojan Nuclear Plant final survey i will include the collection of a minimum of 30 sample measurements per survey unit. For the i majority of c=vey units on the Trojan Nuclear Plant site, conducting 30 sample measurements j
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l VPN-054-99 l August 5,1999 Page 3 of 5 per survey unit results in a statistical confidence in the survey unit conclusion of greater than ,
99.5%, which exceeds the minimum confidence level of 95% specified in NRC guidance.
Re-Submittal of PGE-1078," Trojan Nuclear Plant License Termination Plan" In consideration of paperwork reduction and efficiencies of preparation and review, only the affected sections of the Trojan Nuclear Plant License Termination Plan are being resubmitted.
The affected sections include Section 5," Final Survey Plan," which is directly impacted, and l
front matter including the Table of Contents, List of Tables, and List of Effective Pages, which are indirectly affected by the additional detail added to Section 5. The attached sections of the Trojan Nuclear Plant License Termination Plan, including Section 5, replace the previous corresponding sections in their entirety. Attachment III to this letter provides the revised sections of the Trojan Nuclear Plant License Termination Plan, as well as instructions for the :
insertion of the revised sections into the controlled Trojan Nuclear Plant License Termination l Plan binders submitted on March 10,1999. !
I Attachment III, together with the Trojan Nuclear Plant License Termination Plan submitted by ;
PGE letter VPN-007-99 dated March 10,1999, satisfies the requirements of 10 CFR 50.82(a)(9) l to submit for review and approval a License Termination Plan. In accordance with 10 CFR 50.82(a)(9)(i), the Trojan Nuclear Plant License Termination Plan is submitted as a ;
supplement to the Trojan Defueled Safety Analysis Report; therefore, ten additional copies of the l replacement sections, including Section 5, are provided in accordance with 10 CFR 50.4(b)(6).
To assist the NRC Staffin their review of the Final Survey Plan portion of the Trojan Nuclear Plant License Termination Plan, area maps depicting a " snapshot" of the survey units that have i been established as of the date of this letter are provided as supplementary information in Attachment IV. Since final survey activities at the Trojan Nuclear Plant site are being conducted I in parallel with dismantlement and decontamination activities, some areas (e.g., embedded piping and specified systems) have not yet been divided into survey units. Furthermore, since ongoing remediation and other practical considerations may cause the reconfiguration of several survey units, the final configuration of all survey units is not yet established. Therefore, these maps are provided as supplemental infonnation not formally incorporated into the Trojan Nuclear Plant License Termination Plan. Submittal of the requested detailed maps in this manner precludes the potentially onerous resource commitment to continually conduct extensive and repeated revision of these maps as decommissioning and final survey activities progress.
Notwithstanding the above, PGE has included in the Final Survey Plan section a table summarizing the survey unit designations and characteristics as they are configured to date.
Reconfigurations and continued survey unit design activities will continue in accordance with the methodology, rules, and constraints described in Section 5. " Final Survey Plan," of the Trojan Nuclear Plant License Termination Plan, and pursuant to the License Termination Plan change l
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F VPN-054-99 August 5,1999 Page 4 of 5 criteria proposed in the attached LCA 247, Revision 1. This methodology is applied to selecting, sizing, classifying, and gathering and evaluating data from survey units.
LCA 247, Revision 1 In addition to forwarding the Trojan Nuclear Plant License Termination Plan, PGE letter VPN-007-99 submitted LCA 247, which requested amendment of Facility Operating (Possession Only) License No. NPF-1. LCA 247 proposed to add a license condition denoting NRC approval of PGE-1078," Trojan Nuclear Plant License Termination Plan." LCA 247 has been revised to
- 1) reflect the changes made to the Trojan Nuclear Plant License Termination Plan as incorporated into Attachment III to this letter,2) incorporate additional License Termination Plan change criteria into the license as requested by the NRC during the aforementioned telephone communications, and 3) reflect the current condition of the Trojan Nuclear Plant license basis.
The proposed change criteria discussed in Item 2 above specify the conditions under which changes to the Trojan Nuclear Plant License Termination Plan would require prior NRC approval.
The revised LCA 247 and affected license condition are provided in Attachments I and II to this letter. These attachments supersede Attachments I and II to PGE letter VPN-007-99.
Attachment I to this letter provides Revision 1 to LCA 247, including the background and reason for the proposed change, a description of the proposed change, a no significant hazards
.' consideration determination, and an environmental impact consideration determination. To assist the NRC in its review, changes to LCA 247 have been identified by a vertical line in the right-hand margin adjacent to the afTected text.' Attachment II provides a copy of the affected Facility Operating (Possession-Only) License No. NPF-1 page with changes annotated.
Conclusion This letter is submitted under oath and affirmation as required by 10 CFR 50.30(b). Also attached is one signed copy of a Certificate of Service for LCA 247, Revision 1, to the Chief Executive of the County in which the facility is located and to the Director of the Oregon Oflice of Energy.
l Considering the progress of decommissioning activities at the Trojan Nuclear Plant under the approved Decommissioning Plan, your timely review is requested to support the conduct of operational surveys. If you have any questions regarding this correspondence, please contact Lanny Dusek of my staff at (503) 556-7409.
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p VPN-054-99 August 5,1999 '
Page 5 of 5 i-Sincerely,
%% =g Stephen M. Quennoz Vice President Nuclear and Thermal Operations Attachments c: - L. H. Thonus, NRC, NRR M. T. Masnik, NRC, NRR (w/o)
S. A. Richards, NRC, NRR (w/o)
S. W. Brown, NRC, NMSS (5)
, T. C. Johnson, NRC, NMSS (w/o)
J. T. Greeves, NRC, NMSS (w/o)
Director, NMS, NRC Region IV D. Stewart-Smith, OOE (w/o)
A. Bless, OOE P. Genoa, NEI (w/o) 1 i
STATE OF OREGON, )
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COUNTY OF COLUMBIA )
I, S. M. Quennoz, being duly sworn, subscribe to and say that I am the Vice President Nuclear and Thermal Operations for Portland General Electric Company, the licensee herein; that I have full authority to execute this oath; that I have reviewed the foregoing; and that to the best ofmy knowledge, information, and belief the statements made in it are true.
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Date MkST b ,1999 i
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S. M. Quennoz, Vice President Nuclear and Thermal Operations Portland General Electric Company I
On this day personally appeared before me, S. M. Quennoz; to me known to be the individual l who executed the foregoing instrument, and acknowledged that he signed the same as his free act.
GIVEN under my hand and seal thisN day of ALAbLL5~T ,1999.
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0Frcaa No@ublic in and for the O CNIBf K.CASCIATO NUTW PUBLC-0EGON coWSSION NO.32M3B WCONS$10N DMES AAY 27,2W3 State of Oregon l
Residing at 06 A- W
, My commission expires 7/47/ c3 l t
UNITED STATES OF AMERICA l l NUCLEAR REGULATORY COMMISSION I In the Matter of )
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PORTLAND GENERAL ELECTRIC COMPANY ) Docket 50-344 THE CITY OF EUGENE, OREGON, AND ) License NPF-1 PACIFIC POWER & LIGHT COMPANY )
(TROJAN NUCLEAR PLANT) )
CERTIFICATE OF SERVICE I hereby certify that copies of License Change Application 247, Revision 1, to the Operating License for the Trojan Nuclear Plant, dated August 5,1999, have been served on the following by hand delivery or by deposit in the United States Mail, first class, this 5th day of August 1999:
State of Oregon l Attn: David Stewart-Smith Oregon Office of Energy 625 Marion Street NE Salem, Oregon 97301-3742 Chairman of County Commissioners Columbia County Courthouse 1 St. Helens, Oregon 97051
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ans' O. Dusek '
Manager, Nuclear Regulatory Affairs On this day personally appeared before me Lansing G. Dusek, to me known to be the individual who executed the foregoing instrument, and acknowledged that he signed the same as his free act.
GIVEN under my hand and seal this 5th day of August 19 9.
mg Notary cvs h d-in an for the State orDregon 9 CHIDTLCASCIATO NOTARYPUBUC-0EGON COMMIS$10N NO. 323838 wcONSSON DMSJULY 27.2003 Residing atMW whD
,A My commission expires 7 67/63 *
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j-1 ATTACHMENTI to VPN-054-99 1
LICENSE CHANGE APPLICATION (LCA) 247, REVISION 1 LICENSE AMENDMENT FOR APPROVAL OF PGE-1078,
" TROJAN NUCLEAR PLANT LICENSE TERMINATION PLAN" l
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Attachment I -
VPN-054-99 August 5,1999 Page1of5' LICENSE CHANGE APPLICATION (LCA) 247, REVISION 1 LICENSE AMENDMENT FOR APPROVAL OF PGE-1078,
" TROJAN NUCLEAR PLANT LICENSE TERMINATION PLAN" TABLE OF CONTENTS Background and Reason for the Change .......................................................................................... .. 2 Desc ri pti o n o f Change . . . . . . . . . .. .. . .. . . . .. . . . . . . . . . . . . . . . .. . . . .. . . . . . . . . .. . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
No Significant Hazards Consideration Determination....................................................................... 3 Environmental Impact Consideration Determination ........................................................................ 4 S ched ule Consi deration .... . ...... .... .. . . ... ....... . . ....... ... .... . .. ... .... .. . .... ... . .. . ... . .. ........ ...... . .. . ....... .... .. .. . ..... 5 i
Attachment I VPN-054-99 August 5,1999 j Page 2 of 5 l
- 1. Background and Reason for the Change Portland General Electric Company (PGE) announced permanent cessation of power operations of the Trojan Nuclear Plant (TNP) on January 4,1993. PGE submitted a proposed TNP Decommissioning Plan and Environmental Report Supplement on January 26,1995, which were approved by the Nuclear Regulatory Commission (NRC) on April 15,1996. The facility currently is undergoing active decontamination and dismantlement in accordance with the approved TNP Decommissioning Plan.
The TNP Decommissioning Plan was submitted and approved in accordance with the NRC's rule l
governing decommissioning and termination oflicense,10 CFR 50.82," Application for Termination of License." This rule has since been revised. The revised rule, specifically ;
10 CFR 50.82(a)(9), requires all power reactor licensees to submit a license termination plan, )
either prior to or with the licensee's application for license termination, for NRC approval at least '
two years before termination of the license date. Attachment 111 to PGE letter VPN-007-99, dated i March 10,1999, submitted for NRC approval PGE-1078," Trojan Nuclear Plant License l Termination Plan." Attachment III to VPN-054-99, dated August 5,1999, re-submits the final j survey plan portion of the Trojan Nuclear Plant License Termination Plan. Therefore, '
VPN-054-99, Attachment III, together with the Trojan Nuclear Plant License Termination Plan i submitted on March 10,1999, satisfies the requirement of 10 CFR 50.82(a)(9) to submit for !
approval a License Termination Plan. !
I 10 CFR 50.82(a)(10) also stipulates that the License Termination Plan shall be approved by license amendment, subject to such conditions and limitations as the NRC deems appropriate and i necessary. This proposed license change, provided as Attachments I and 11 to VPN-054-99, is l submitted to satisfy the requirement of 10 CFR 50.82(a)(10) for approval of the License Termination Plan by license amendment.
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- 2. Description of Change PGE proposes to amend the license to incorporate a new License Condition 2.C (11), as provided below. Attachment II contains the annotated License Conditions page.
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Attachment i VPN-054 August 5,1999 Page 3 of 5 -
"(I1) LicenseTermination The licensee shall implement and maintain in effect all provisions of the approved License i Termination Plan as described in PGE-1078, " Trojan Nuclear Plant License Termination Plan," and as approved in the SER dated . The licensee may make changes to PGE-1078 without prior approval provided the proposed changes do not: ;
(a) Involve an unreviewed safety question or changes to the technical specifications as specified in 10 CFR 50.59-(b) Violate the requirement:: of 10 CFR 50.82(a)(6); .
(c) Reduce the coverage requirements for scan measurements;
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(d) Increase the radioactivity level, relative to the applicable derived concentration i guideline level, at which an investigation occurs; or ;
(e) Change the statistical test applied to the final survey data to one other than the Sign test or the Wilcoxon Rank Sum test." 1
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- 3. No Significant Hazards Consideration Determination '
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- In accordance with the requirements of 10 CFR 50.92, " Issuance of Amendment," this license amendment request conforms to the standards for a determination of no significant hazards ;
consideration based upon the following:
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- 1. The proposed license amendment does not involve a significant increase in the probability i or consequences ofan accident previously evaluated.
The requested license amendment does not authorize additional plant activities beyond those that already~ may be conducted under the approved TNP Decommissioning Plan and the Defueled Safety Analysis Report (DSAR). Accident analyses are included in the approved TNP Decommissioning Plan and incorporated into the TNP DSAR. No systems, structures, or components that could initiate or be required to mitigate the consequences of an accident are affected by the proposed change in any way not previously evaluated in the approved TNP Decommissioning Plan and DSAR. Therefore, the proposed change is administrative in nature and as such does not involve a significant increase in the probability or consequences of an accident previously evaluated.
Attachment I VPN-054-99 August 5,1999 Page 4 of 5
- 2. The proposed license amendment does not create the possibility ofa new or different kind ofaccidentfrom any accident previously evaluated.
The requested license amendment does not authorize additional plant activities beyond those that already may be conducted under the approved TNP Decommissioning Plan and the DSAR. Accident analyses are included in the approved TNP Decommissioning Plan and incorporated into the DSAR. The proposed change does not affect plant systems, structures, or components in any way not previously evaluated in the approved TNP Decommissioning Plan and DSAR, and no new or different failure modes will be created.
Therefore, the proposed change is administrative in nature and as such does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. The proposed license amendment does not involve a sigmficant reduction in a margin of safety.
Approval of the TNP License Termination Plan by license amendment is administrative in nature since the decommissioning and fuel storage activities described in the TNP License Termination Plan are consistent with those in the approved TNP Decommissioning Plan and DSAR. Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the preceding analysis, it is concluded that the requested amendment to Trojan Facility Operating (Possession Only) License NPF-1 is acceptable, and involves no significant hazards consideration as defined in 10 CFR 50.92.
- 4. EnvironmentalImpact Considerations Determination This amendment request satisfies the criteria specified in 10 CFR 51.22(c)(9) for a categorical exclusion from the requirements to perform an environmental assessment or to prepare an environmental impact statement. The specific criteria of 10 CFR 51.22(c)(9) are addressed as follows:
(i) The amendment involves no sigmficant ha:ards consideration.
As demonstrated above, the proposed amendment does not involve a significant hazards consideration.
(ii) There is no sigmficant change in the 13 pes or sigmficant increase in the amounts ofany effluents that may be released ofpite.
The requested license amendment does not authorize additional plant activities beyond those that may already be conducted under the approved TNP Decommissioning Plan and the DSAR. The TNP Supplement to Applicant's Environmental Report - Post Operating License Stage, prepared and submitted in conjunction with the TNP Decommissioning Plan
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VPN-054-99 August 5,1999 Page 5 of 5 i
. and approved by the NRC, concluded that decommissioning activities would be l
accomplished with no significant adverse environmental impacts. The TNP License Termination Plan evaluates this conclusion and determines that there is no new information i or significant environmental change associated with activities described in the TNP License l
Termination Plan. Thus, the proposed change will result in no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.
(iii) There is no sigm*ficant increase in individual or cumulative occupational radiation exposure.
i The requested license amendment does not authorize additional plant activities beyond those that may already be conducted under the approved TNP Decommissioning Plan and the DSAR. The TNP Supplement to Applicant's Envirotunental Report - Post Operating l License Stage, prepared and submitted in conjunction with the TNP Decommissioning Plan and approved by the NRC, concluded that decommissioning activities would be accomplished with no significant adverse environmental impacts. The TNP License j Termination Plan evaluates this conclusion and determines that there is no new information or significant environmental change associated with activities described in the TNP License Termination Plan. Thus, the proposed change will result in no significant increase in individual or cumulative occupational radiation exposure.
Based on the preceding analysis, it is concluded that the proposed change to the TNP license satisfies the criteria delineated in 10 CFR 51.22(c)(9) for categorical exclusion from the requirements of an environmental impact statement or environmental assessment.
- 5. Schedule Consideration Following approval, it is requested that 30 days be provided for implementation of this amendment.
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ATTACHMENTII to VPN-054-99 ANNOTATED LICENSE PAGE
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(5) The licensee may proceed with and is required to complete the modifications identified in Paragraphs 3.1.1 through 3.1.18 of the NRC Fire Protection Safety Evaluation Report on the Trojan Nuclear Plant dated March 22,1978. These modifications shall be completed by the end of the second refueling outage of the Trojan facility and prior to return to operation for Cycle 3. In addition, the licensee )
shall submit the additional information identified in Table 3.2 of this Safety Evaluation Report in accordance with the schedule contained therein. In the event these dates for submittal cannot be met, the licensee sha!! submit a report explaining the circumstances, together with a revised schedule.
(6) Primarv Shieldino Modification The licensee is authorized to modify the primary shielding design as described in PGE letter dated April 22,1977, as supplemented and amended by letters dated September 22 and 23,1977, December 22,1977, January 4 and 24,1978, March 20, and April 4,1978.
(7) Soent Fuel Assembiv Shiocino Cask Deleted (Amendment 196) 6 I
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(8) Fire Protection l l
The licensee shallimplement and maintain in effect all provisions of the approved l i ! fire protection program as described in PGE-1012, " Trojan Nuclear Plant Fire l Protection Plan" and as approved in the SER dated September 22,1993 subject to l l the following provision:
l l192 The licensee may make changes to the approved fire protection l program without prior approval of the Commission only if those l changes would not adversely impact the safe storage of l irradiated fuel or increase the likelihood of an offsite release of l radioactive material due to a fire. l (9) Soent Fuel Pool Debris Processino l l
The licensee is authorized to process spent fuel pool debris in accordance with PGE l ' 9 i.
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l (10) Loading of Fuel into Casks in the Fuel Building l I
I I The licensee is authorized to load spent nuclear fuel and other mraerials into I transfer and storage casks in the Fuel Building in accorent w;th License Change h9g Application (LCA) 237, transmitted by PGE letter dated January 7,1999, and LCA l 246, transmitted by PGE letter dated January 27,1999. Changes to LCA 237 and LCA 246 are permitted without changing this license providing they are evaluated in (00 r
i accordance with 10 CFR 50.59 and reported in accordance with 10 CFR 50.7(e). l TNSERT A >
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- (11) License Termination The licensee shall implement and maintain in effect all provisions'of the approved License Termination Plan as described in PGE-1078, " Trojan Nuclear Plant License Termination Plan," and as approved in the SER dated . The licensee 2 may make changes to PGE-1078 without prior approval provided the proposed changes do not:
(a) Involve an unreviewed safety question or changes to the technical specifications as specified in 10 CFR 50.59; (b) Violate the requirements of 10 CFR 50.82(a)(6);
(c) Reduce the coverage requirements for scan measurements; 1
(d) . Increase the radioactivity level, relative to the applicable derived concentration
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guideline level, at which an investigation occurs; or J (e) Change the statistical test applied to the final survey data to one other than the Sign test or the Wilcoxon Rank Sum test.
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