ML20212J328

Forwards Amend 22 to PGE-1012, Trojan Nuclear Plant Fire Protection Plan, IAW 10CFR50.48(f).Amend Reflects Revs Made During Decommissioning Activities & Does Not Reduce Effectiveness of Fire Protection

ML20212J328
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	06/15/1999
From:	Quennoz S PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20212J330	List: ML20212J328
References
VPN-051-99, VPN-51-99, NUDOCS 9906290217
Download: ML20212J328 (9)

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7 Portland General Electric Company Trojan Nuclear Plant 71760 Columbia River Hwy Rainier OR 97048 (5031556 3723 June 15,1999 VPN-051-99 Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission A'ITN: Document Control Desk ,

Washington, DC 20555 Irojan Nuclear Plant Fire Protection Plan. Amendment 22. PGE-1012 This letter documents the transmittal of eleven copies of Amendment 22 to PGE-1012, " Trojan

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Nuclear Plant Fine Protection Plan." In accordance with 10 CFR 50.48(f), Amendment 22 reflects revisions to the Fire Protection Program made during decommissioning activities. The changes do not reduce the effectiveness of fire protection for facilities, systems, and equipment l

which could result in a radiological hazard, and take into account the decommissioning plant conditions and activities.

PGE certifies that Amendment 22 accurately presents changes to PGE-1012 since the previous l

! submittal of Amendment 21, necessary to reflect information and analyses submitted to the Commission or prepared pursuant to Commission requirements.

Sincerely, .

!l Stephen M. Quennoz Vice President, Nuclear 99 p b 7 h 5 PDR ADOCK 05000344 and Thermal Operations '

F PDR Attachment Enclosure l

c: Director, NRC NMS, Region IV L. H. Thonus, NRC, NRR D. Stewart-Smith, OOE l

lL' Connecting People, Power and Possibilities g a

Attachment to VPN-051-99 June D,1999 Page1 of5 Sumniary Description of Channes The following table provides a synopsis of the changes incorporated into PGE-1012, Amendment 22. These changes have been evaluated and determined not to involve an unreviewed safety question as required by 10 CFR 50.59.

These changes also have been shown to meet the criteria of Amendment No.192 of Trojan Possession Only License, NPF-1, in that the changes do not adversely impact the safe storage of irradiated fuel or increase the likelihood of an offsite release of radioactive material due to a fire.

Section Description Discussion / Justification All General Notes Extensive portions of PGE-1012 were based on operational concerns that are no longer relevant due to the extensive removal of equipment from the power block, reduction t in combustible loading, and lack ofimpact on the safe storage ofirradiated fuel. This information is removed.

Original design basis information that was required to show compliance with Appendix A to BTP 9.5-1 and Appendix R to 10 CFR 50 is deleted from PGE-1012.

I The Plan is re-focused on NFPA compliance.

1.1 Add description of the Independent ISFSI construction is completed.

Spent Fuel Storage Installation (ISFSI) l l

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. Attachment to VPN-051-99 June 15,1999

. Pane 2 of 5 Section Description Discussion / Justification 1.2 Revise text to reflect advanced stage Update the basis for the Plan to more ofdecommissioning. directly reflect decommissioning progress in accordance with 10 CFR 50.48(f). The Add evaluation of compliance with update includes discussions of compliance of 10 CFR 50.48(f). the updated Plan with governing federal and -

state regulations. It also includes a Fire Add summary of Fire Hazards Hazards Analysis summary to support Analysis from deleted Chapter 4. 10 CFR 50.48(f).

Add evaluation of compliance with -

Oregon Administrative Rule (OAR) 345-026-0360.

1.3 . Revise background description to Reduced background information provides reduce detail regarding previous the required history of development relative amendments.

to Plant decommissioning.

Add description of this Amendment. New description explains logic applied to j this Amendment. j 1.4 Revise Plan overview to match Editorial: based on other changes.

changes in the Plan.  ;

2.0 Move introductory text to . Editorial: consolidates similar text.

Section 2.2 '

2.1 Revise Organization section to These positions do not have any special ,

delete reference to Manager, duties rela'tive to the Trojan Fire Protection  ;

Maintenance; General Manager, Plan. The duties listed are the same for other Plant Support; Manager, Personnel Plant programs and do not add value to the Protection; Manager, Operations; Plan.  ;

Loss Prevention Engineer; Nuclear  ;

Oversight; Independent Review and Audit Committee; and Manager, i Licensing. '

2.1.10. Revise description of Fire Protection Editorial: consolidates similar duties.  ;

Engineer duties.

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l Attachment to VPN-051-99

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Pane 3 of 5

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I Section Description - Discussion / Justification i 2.1.16 Revise personnel qualifications. Deleted section was specific to compliance with BTP 9.5-1 which is no longer applicable.

2.2 Revise text to reduce level of detail. Details are contained in Plant procedures.

Evaluation of applicability of PGE-8010," Quality Assurance Program," moved from Section 2.4.

2.3 - Revise text to reduce level of detail. Detail is generic to fire brigades and contained in Plant procedures.

2.4 Revise text to reduce level of detail. Previous text focused on what was not j quality related. This information is Move Quality Assurance evaluation historical.

z to Section 2.2.  !'

Diesel fire pump changed to non-quality i related based on revised evaluation.

1 3.0 This section is extensively revised. Editorial: consolidates similar text.  !

The introduction is combined into Section 3.1, 3.1 Fire barriers are reduced in scope l Fire barriers are reduced to those required to and moved to Section 3.4.1. protect egress paths based on reduction in - ]

l combustible loading.

Revised Section 3.1 contains Code l applicability from previous

l. Section 3.9 and portions of  !

Section 3.0.

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Section Description - Discussion / Justification 3.2, Revise text to reduce level of detail. Extensive level of detail was related to 3.3, original design compliance with Appendix A and 3.4 Text moved to new Section 3.4.4. to BTP 9.5-1 and ' operator actions required

_ for Appendix R to 10 CFR 50. This level of detailis historical.

Revised text retains NFPA Code reference and general descriptions.

Suppression System Failure Analysis was required for protection ofelectrical equipment that is no longer safety related.

3.5 Revise text to reduce level of detail. Delete system design details. Details of system operation are not unique to Trojan -

Text moved to new Section 3.4.5, and are controlled by the Plant design process.

3.6 Revise text to reduce level of detail. Delet'e BTP 9.5-1, Appendix A reference.

Text moved to Section 3.4.2. Added criteria for areas that are being vacated during decommissioning.

3.7 Revise text to reduce content. Details of radio type and phone use are not unique to Trojan or the Fire Protection Plan.

Text moved to Section 3.4.3.

3.8 Delete Operability Specifications. The Operability Specifications were originally Technical Specification surveillances required to protect safety related equipment and to ensure safe shutdown. These criteria are no longer

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i applicable. The remaining surveillances, inspection, and maintenance are based on NFPA Code requirements and are outlined in implementing Plant procedures. Only the fire barrier criteria is significantly reduced based on the lack of combustible loading.

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- Attachment to VPN-051-99 June 15,' 1999 Page5 of5 Section Description Discussion / Justification

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3.9 Text moved to Section 3.1. Editorial: consolidates similar text.

Add text from previous Section 3.0.

Table Delete. Required fire barriers are reduced based on 3.1-1* reduced installed equipment and combustible loading.

l l Tables Delete. Active sprinklers and deluge systems are 3.3-1 listed in Plant testing procedures.

and 3.3-2 Table Delete Active detectors are listed in Plant 3.5-1 procedure.

Table Re-number to Table 3-1. Editorial.

3.9-1 4.0 Delete. The Fire Hazards Analysis Text is revised to reduce detail. Changes -

, is summarized in Section 1.2.1. reflect progress in Plant decommissioning Details are retained in Civil Fire - resulting in greatly reduced levels ofin-situ

Protection File, C-FP-2.0. combustible loading in the power block.

L L Structural design information in the section is historical and not likely to be changed by fire protection criteria.

5.0- Delete. This section demonstrated compliance with A pendix A to BTP 9.5-1 which is no longer appi! cable due to Plant system removal.

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1 l-LGD-077-99 t

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From: L. G. Duse ,

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' Da'e: June 10,1999 I

Subject:

Transmutal of Amendment 22 to PGE-1012, Troian Nucienr Plant Fire Protection Plan Enclosed is your copy of Amendment 22 to PGE-1012, Trojan Nuclear Plant Fire Protection Plan. Amendment 22 replaces PGE-1012 in its entirety. ,

, Please acknowledge receipt of your copy by completing the lower portion of this transmittal and returning it to the location given below.

• LGD/CKC Enclosure 6/10/99 ACKNOWIFnGMENT Amendment 22 PGE-1012, Trojan Nuclear Plant Fire Protection Plan I hereby acknowledge receipt of Controlled Copy Number (s) of the subject docuffant. Ali chaliges have bedri made in accordance with the instructions, and superseded l pages have been destroyed.

I Signature of Copy Holder- Date Return to: Pat Schaffran, TCB-3/ Licensing Trojan Nuclear Plant

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' 71760 Columbia River Highway Rainier, Oregon 97048 L

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TROJAN NUCLEAR PLANT PGE-1012 Fire Protection Plan Amendment 22 The following information is furnished as a guide for inserting new pages for Am into the Trojan Nuclear Plant Fire Protection Plan. Revised pages should be i Insert (Front /Back) i' Delete (Front /Back) i Entire document Entire document l

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TROJAN NUCLEAR PLANT l .-

PGE-1012. Fire Protection Plan. Amendment 22 The following information is furnished as a guide for insening new pages for Amendment 22 into the Trojan Nuclear Plant Fire Protection Plan. Revised pages should be inserted as below:

Delete (Front /Back) Insen (Front /Back) l l Entire document - Entire document l

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