ML20237E942

Requests Exemption of Emergency Plan Requirements of 10CFR50.54(q),10CFR50.47(b) & 10CFR50,App E Following Transfer of Spent Nuclear Fuel to ISFSI

ML20237E942
Person / Time
Site:	Trojan  File:Portland General Electric icon.png
Issue date:	08/27/1998
From:	Quennoz S PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
VPN-014-98, VPN-14-98, NUDOCS 9809010306
Download: ML20237E942 (18)

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l- Portland General Electric Trojan Nudear Plant 71760 Columbia River Hwy Rainier OR 97048 (503)S56-3713 August 27,1998 VPN-014-98 l U. S. Nuclear Regulatory Commission Trojan Nuclear Plant Document Control Desk Docket 50-344 Washington, DC 20555 License NPF-1 l

Exemotion Request and License Change Application (LCA1244 i Deletion of Emergency Plan Requirements from Part 50 License after Fuel Movement to the ISFSI and Reactor Vessel and Internals Removal Pursuant to 10 CFR 50.12 and 10 CFR 50.90, this letter transmits an exemption request and License Change Application (LCA) requesting amendment of Facility Operating (Possession Only) License No. NPF-1. This letter requests exemptiori of the emergency plan requirements of 10 CFR 50.54(q),10 CFR 50.47(b), and 10 CFR 50, Appendix E following the transfer of the spent nuclear fuel to an Independent Spent Fuel Storage Installation (ISFSI) and the removal of the reactor vessel and internals from the Trojan Nuclear Plant (TWP) 10 CFR 50 licensed area.

This exemption request and LCA reflect the reduced potential for radiological consequences from an accident following the permanent removal of the spent nuclear fuel and the reactor

vessel and internals from the 10 CFR 50 TNP licensed area.

Transfer of the spent nuclear fuel from the 10 CFR 50 licensed area cannot commence until approval of a 10 CFR 72 license for the Trojan ISFSL The proposed site of the ISFSI is located within the currently existing 10 CFR 50 licensed area; however LCA-242, submitted by PGE letter dated February 12,1997, requested the removal of the proposed ISFSI -rea from the 10 CFR 50 licensed portion of the site. Application for the 10 CFR 72 ISFSt acense was made by PGE letter dated March 26,1996. The 10 CFR 72 license application, as amended by PGE letters dated April 3,1997, and November 11,1997, included a separate emergency plan specific j// j to the ISFSI. Implementation of this exemption request is predicated on: (1) approval of the //

10 CFR 72 license application, (2) approval of LCA-242, (3) the transfer of the irradiated fuel assemblies to the 10 CFR 72 ISFSI, and (4) the removal of the reactor vessel and internals from .

the 10 CFR 50 licensed area of the Trojan facility site.

g Removal of the reactor vessel and internals from the 10 CFR 50 licensed area of the TNP site is currently awaiting approval for the one-time shipment of the reactor vessel with internals intact

. (reactor vessel package) for disposal at the US Ecology low level radioactive waste facility on the Hanford Reservation near Richland, Washington. Application for the package was made by PGE letter dated March 31,1997, as supplemented. Whether disposal of the reactor vessel and 9e09010306 990e2734 PDR ADOCK 0

z VPN-014-98 August 27,1998 Page 2 of 2 internals is accomplished in accordance with the currently planned method or by another option, removal of the reactor vessel and internals from the 10 CFR 50 licensed area of the site will eliminate approximately 2 million curies of activity from the Trojan Plant. Following the transfer of the spent nuclear fuel to the ISFSI, removal of the reactor vessel and internals will result in removal of greater than 99 percent of the remaining activity at the facility. The remaining radioactive material inventory will be less than the quantities specified in 10 CFR 30.32(i),10 CFR 40.31(j),10 CFR 70.22(i), and 10 CFR 30.72," Schedule C -

Quantities of Radioactive Materials Requiring Consideration of the Need for an Emergency Plan for Responding to a Release."

Following the permanent cessation of power operations and reactor vessel defueling, PGE requested exemption from certain prescribed standards contained in 10 CFR 50.47(b) and i 10 CFR 50, Appendix E to allow the elimination of offsite emergency response plans and a reduction in the scope of onsite response measures. This exemption was granted based on the

. significantly reduced potential risk to the public and the limited range of credible accidents and accident cor.requences associated with the non-operating, defueled condition of the plant.

Following th; removal eithe spent nuclear fuel and the reactor vessel and internals from the 10 CFR 50 licensed area of the site, an exemption from the above regulations requiring an emergency plan is justified and hereby requested.

Attachment I provides the background and reason for the proposed exemption and license change, a description of the pcoposed exemption and license change, and a no significant hazards conGeration determination.- Attachment II provides a copy of the affected Technical i Specification page with changes annotated.

This letter is submitted under oath and affirmation as required by 10 CFR 50.30(a)(6)(b). Also attached is one signed copy of a Certificate of Service for LCA-244 to the Chief Executive of the County in which the facility is located and to the Director of the Oregon Office of Energy.

I Sincerely, f , .__, q m Stephen M. Quennoz Trojan Site Executive Attachments c: L. H. Thonus, NRC, NRR  !

T. J. Kobetz, NMSS R. A. Scarano, NRC Region IV David Stewart-Smith, OOE

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STATE OF OREGON, ) 4

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COUNTY OF COLUMBIA )

I, S. M. Quennoz, being duly sworn, subscribe to and say that I am the Trojan Site Executive, 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 of my knowledge, information, and belief the statements made in it are true.

Date Augtut 27 ,1998 I

l E _% ==/ l S. M. QuennY l Trojan Site Executive  ;

Portland General Electric Company l l

On this day personally appeared before me, S. M. Quennoz; to me known to be the individual  !

who executed the foregoing instrutnent, and acknowledged that he signed the same as his free - i act.

I th GIVEN under my hand and seal this 27 day of August ,1998.

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k cE^M N YofsY7 tate of Oregon l MY COMMISSION EXPIRES JULY 27.1999 l u l Residing atR /o d[eMiGTI l

My commission expires 7/ M '

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I UNITED STATES OF AMERICA l

, , NUCLEAR REGULATORY COMMISSION  !

In the Matter of .)

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PORTLAND GENERAL ELECTRIC COMPANY ) Docket 50-344 THE CITY OF EUGENE, OREGON, AND ) Operating License NPF-1 PACIFIC POWER & LIGIIT COMPAN Y )

(TROJAN NUCLEAR PLANT) )

CERTIFICATE OF SERVICE I hereby certify that copies of License Change Application 244 to the Operating License for the Trojan Nuclear Plant, dated August 27,1998, have been served on the following by hand delivery or by deposit in the United States Mail, first class, this 27th day of August 1998:  ;

i State of Oregon l

Attn: David Stewart-Smith i Oregon Office of Energy 625 Marion Street NE Salem, Oregon 97310 j l

Chairman of County Commissioners Columbia County Courthouse St. IIelens, Oregon 97051 j

H. R. Pate Manager, Licensing, Compliance, and Commitment Management

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On this day personally appeared before me H. R. Pate, 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 27th day of August,1998, an e omsm Notary Pyin and for the State of Oregon Cil10YK.CASCIATO NOTARYPUBUC@EGON uyco m E N EyS7$#1999 Residing atO/1/>NA//4 O, O~S i My commission expires 7 b7 l

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i VPN 014-98 Attachment I August 2'7,1998 l

Page1o[Il L-TABLE OF CONTENTS 1.- BACKGROUND AND REASON FOR CHANGE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 i

2. ' DESCRI PTION OF CHANG E . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . g j

3. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION . . . . . . . . . . . . 10 1

' 4. SC'HEDULE CONSI DERATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 1

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[ VPN-014-98 Attachment I 1 August 27,1998 L . Ppge 2 0(il -

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1. Background and Reason for the Exemption and License Change

Background

On January 27,1993, after approximately 17 years of operation, Portland General Electric y Company (PGE)' notified the Nuclear Regulatory Commission (NRC) ofits' decision to

permanently cease power operations. By letter dated February 2,1993, PGE certified to the

.' NRC that the reactor core was permanently defueled, placing the Trojan Nuclear Plant (TNP) in -

' a permanent shutdown status with the spent nuclear fuel permanently removed from the reactor i vessel. The NRC amended the TNP Facility Operating License (NPF-1) to a Possession Only License on May 5,1993.

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.10 CFR 50.54(q) requires that licensees authorized to possess or operate a power reactor shall follow and maintain in efTect emergency plans which meet the standards in 10 CFR 50.47(b) and the requirements contained in 10 CFR 50, Appendix E.' Following the permanent cessation of =

L _ power operations and reactor vessel defueling, PGE requested exemption from certain prescribed standards contained in 10 CFR 50.47(b) and 10 CFR 50, Appendix E to allow the elimination of offsite emergency response plans and a reduction in the scope of onsite response

. measures. - This exemption sequest'was made by PGE letter dated March 9,1993, as supplemented on September 14,1993.

In a separate letter, also dated March 9,1993 and revised on September 23,1993, PGE submitted l

, - the Trojan Nuclear Plant Permanently Defueled Emergency Plan (PGE-1060) to the NRC. - With the reactor permanently defueled and the spent nuclear fuel stored in the spent fuel pool, the potential risk to the public was significantly reduced and the range of credible accidents and j

. accident consequences were limited. A review of credible accidents associated with the

- permanent shutdown and defueled conditions established that a radiological release would not ' i result in offsite' doses which could exceed Environmental Protection Agency (EPA) Protective  !

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. Action Guideline (PAG) limits. As a result of the reduction in credible ofTsite radiological ~

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i VPN-014-98 Attachment I August 27,1998 l Page 3 of11 releases, the primary purpose of the TNP Permanently Defueled Emergency Plan was changed to outline the actions necessary to safeguard Plant personnel and equipment in the event an emergency involves or could potentially involve the release of radioactive material.

On September 30,1993, the NRC granted the requested exemptions from emergency plan

. requirements allowing revision of the Trojan Nuclear Plant Permanently Defueled Emergency Plan.

l As a result of the permanent cessation of power operations, PGE's long term goal is the j decontamination of the facility and termination of the TNP 10 CFR 50 license. As part of the process oflicense termination, the TNP Decommissioning Plan (PGE-1061) was submitted by l PGE on January 26,1995, as supplement.o en November 13,1995. The TNP Decommissioning Plan detailed the prompt decontamination and dismantlement of contaminated structures, systems and components and was approved by the NRC by letter dated December 18,1995. The TNP Decommissioning Plan specified the relocation of the spent nuclear fuel to an Independent Spent Fuel Storage Installation (ISFSI) pending transfer to a federal high level waste repository.

The relocation of the spent nuclear fuel from the spent fuel pool to the ISFSI allows I decontamination and dismantlement of structures, systems, and components of the TNP site and the termination of the 10 CFR 50 license. I l

On March 26,1996, PGE submitted a 10 CFR 72 license application to the NRC for construction ,

and operation of an ISFSI. An Environmental Assessment (EA) related to the construction and operation of the Trojan ISFSI and a Finding of No Significant Impact (FONSI) ras completed l by the NRC staff and transmitted by letter dated, November 25,1996. In addition, the Physical Security Plan for the Proposed Trojan ISFSI received preliminary NRC staff approval, by letter dated November 20,1996. Final approvals are contingent on issuance of a 10 CFR 72 license for i I

the ISFSI. I In accordance with 10 CFR 72.32(a), PGE's 10 CFR 72 license application included an emergency plan for the Trojan ISFSI. By letters dated April 3,1997, and November 11,1997, PGE amended the original license application by providing a revised Trojan Independent Spent

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VPN-014-98 Attachment I '

August 27,1998 Page 4 of11 Fuel Storage Installation Emergency Plan (PGE-1075) to the NRC Staff. The Trojan Independent Spent Fuel Storage Installation Emergency Plan was developed to meet the l requirements of10 CFR 72.32(a).

The Trojan Independent Spent Fuel Storage Installation Emergency Plan (PGE-1075) describes l PGE's plan for responding to emergencies that may arise at the ISFSI. The purpose of the pla: is to outline the actions to be taken to minimize the adverse effects which could result from accidents or off-normal events involving or potentially involving the release of radioactiv-material stored within the ISFSI. The plan describes emergency classification, notifications, communications, response organization and actions, local offsite assistance, facilities, equipment, and the maintenance of emergency preparedness. As part of the 10 CFR 72 emergency plan, L PGE will maintain agreements with local medical facilities to provide assistance in the event of an injury which involves contamination. These provisions will become effective prior to the movement of the first loaded fuel storage cask to the ISFSI.

I On February 12,1997, PGE submitted LCA-242 which requested NRC approval for deleting the -

ISFSI access controlled area from the existing 10 CFR 50 licensed area. NRC approval of LCA-242 is expecteci concurrent with the issuance of the 10 CFR 72 ISFSI license. Approval of LCA-242 will separate the 10 CFR 72 licensed area from the existing 10 CFR 50 licensed area.

' Removal of the reactor vessel and internals is currently planned to be accomplished by a ,

one-time shipment of the vessel with internals intact (reactor vessel package) for disposal at the US Ecology licensed radioactive waste facility on the Hanford Reservation near Richland, Washington. On March 31,1997, PGE submitted a 10 CFR 71 certificate of compliance application to allow shipping of the reactor vessel package. Removal of the reactor vessel and internals from the TNP site will result in eliminating approximately 2 million curies of activity l- from the 10 CFR 50 licensed area. Exclusive of the spent nuclear fuel, the removal of the reactor vessel internals will result in a reduction of greater than 99% of the remaining radioactive material from the 10 CFR 50 licensed area. l l  !

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a VPN-014-98 Attachment I Augbst 27,1998 Page 5 of 1I It is projected that the last spent nuclear fuel assemblies will be transferred to the ISFSI and that the reactor vessel and internals will be transported from the site by February 20,2000.

The TNP Decommissioning Plan provides an analysis of the credible accidents associated with decommissioning activities. Credible decommissioning activities were evaluated to ensure they would not result in an airborne release resulting in radiation exposures in excess of 0.5 rem at the Exclusion Area Boundary. This acceptance criteria was conservatively selected to ensure that decommissioning activities would not create the potential for exceeding EPA PAGs established in EPA 400-R-92-001," Manual of Protective Action Guides and Protective Actions for Nuclear Incidents," October 1991 at the Exclusion Area Boundary.

i With the spent nuclear fuel and the reactor vessel and internals removed from the 10 CFR 50 licensed area of the site, the radiological source term for credible accident scenarios will be significantly reduced. The remaining radioactive material will consist of activated material contained wnhin the concrete bioshield wall (423 curies or approximately 48%), sealed source j material (415 curies or approximately 47%) and contaminated materials within plant systems (36.7 curies or approximately 5%).

The activation products contained within the bioshield wall and the sealed source material are not in a form that is readily dispensable, however, small quantities of concrete dust could be created during decontamination and dismantlement of the bioshield wall. The remaining activity located within plant systems or structures is not concentrated but distributed throughout the plant.

In the event decommissioning activities result in personnel contamination complicated by injuries, treatment at local medical facilities will remain available via agreements in place to support the 10 CFR 72 emergency plan.

The quantities of radioactive material remaining at the Trojan facility following the transfer of the spent nuclear fuel assemblies and removal of the reactor vessel and internals from the 10 CFR 50 licensed area will be less than the quantities specified in 10 CFR 30 (Rules of General Applicability to Domestic Licensing of Byproduct Material),10 CFR 40 (Domestic Licensin;; of Source Material) and 10 CFR 70 (Domestic Licensing of Special Nuclear I

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VPN-014-98 Attachment I August 27,1998 Page 6 of11 Material) requiring implementation of an emergency plan. Each of these requirements are discussed below.

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10 CFR 30.32(i)(1) contains the following requirements for Byproduct Material Licensees:

"Each application to possess radioactive materials in unsealedform, onfails, orplated sources, or sealed in glass in excess ofthe quantities in S30. 72, "Schedide C--Quantities ofRadioactive Materials Requiring Consideration ofthe Needfor an Emergency Planfor Responding to a Release " must contain either:

(i) An evaluation showing that the maximum dose to aperson offsite due to a release ofradioactive materials would not exceed 1 rem effective dose equivalent or 5 rems to the thyroid; or (ii) An emergencyplanfor responding to the release ofradioactive material. "

Upon completion of the transfer of the spent nuclear fuel to the 10 CFR 72 licensed ISFSI, and the removal of the reactor vessel and internals, the remaining quantities of radioactive materials within the 10 CFR 50 licensed area will be less than the quantities in {30.72.

10 CFR 40.31(j)(1) contains the following requirements for Source Material Licensees:

"Each application to possess uranium hexafluoride in excess of50 kilograms in a single container or 1000 kilograms total must contain either:

(i) An evaluation showing that the maximum intake ofuranium by a member ofthepublic due to a release would not exceed 2 milligrams; or (ii) An emergencyplanfor responding to the radiological release of source material and to any associated chemical ha:ards directly incident thereto. "

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VPN-014-98 Attachment I August 27,1998 Ppge 7 of 11 Uranium hexafluoride is used during the enrichment process of manufacturing nuclear fuel and was not used or produced during the operation of the TNP. Therefore, the quantities of uranium h hexafluoride within the TNP 10 CFR 50 licensed area are less than the quantities specified in

{40.310)(1).

10 CFR 70.32(i)(1) contains the following requiren'ents for Special Nuclear Material Licensees:

"Each application topossess enriched uranium orplutoniumfor which a criticality accident alarm system is required, uranium hexafluoride in excess of50 kilograms in a single container or 1000 kilograms total, or in excess of2 curies ofplutonium in unsealedform or onfoils orplatedsources, must contain either:

(i) A evaluation showing that the maximum dose to a member ofthe public offsite due to a release ofradioactive materials would not exceed I rem effective dose equivalent or an intake of2 milligrams of soluble uranium, or (ii) An emergencyplanfor responding to the radiological ha:ards of an accidental release ofspecici nuclear material and to any associated chemical ha:ards directly incident thereto. "

Upon completion of the transfer of the spent nuclear fuel to the 10 CFR 72 licensed ISFSI, the remaining quantities of enriched uranium or plutonium will be less than the quantities in

@70.32(i)(1).

The quantities of radioactive material remaining at the Trojan facility following the transfer of the spent nuclear fuel assemblies and removal of the reactor vessel and internals from the 10 CFR 50 licensed area will be less than the quantities specified in 10 CFR 30.32(i),

10 CFR 40.310),10 CFR 70.22(i) and 10 CFR 30.72, " Sche'dule C-Quantities of Radioactive Materials Requiring Consideration of the Need for an Emergency I%n for Responding to a Release," which establish ti.c dacshold at which emergency plans for r ponding to the radiological hazards of an accidental release of radioactive material are required. l l

VPN-014-98 Attachment I August 27,1998 l

Page 8 ofil PGE, therefore, requests exemption, pursuant to 10 CFR 50.12, from the emergency plan requirements of 10 CFR 50.54(q),10 CFR 50.47(b), and 10 CFR 50, Appendix E for the 10 CFR 50 licensed area of the Trojan facility. The exemption and license change will permit

more effective utilization of decommissioning financial resources. Funds which would otherwise be used to support emergency plan requirements for the Trojan Plant would be available to perform decommissioning operations.

2. Description of Exemption Request and License Change  ;

The purpose of the emergency plan requirements is to provide reasonable assurance that adequate protection can and will be taken in the event of a radiological emergency. These requirements are based on the presence of a radiological source term for credible accident scenarios.

Movement of the spent nuclear fuel from the Trojan Plant to the ISFSI and removal of the reactor j vessel and internals from the 10 CFR 50 licensed area of the site removes the available radiological source terms for credible accident scenarios.- There is no purpose in having an emergency plan when there is not a potential for a radiological emergency. PGE, therefore, j requests exemption, pursuant to 10 CFR 50.12, from the requirements ef 10 CFR 50.54(q),10 CFR 50.47(b), and Appendix E for the 10 CFR 50 licensed area of the Trojan facility.

Maintaining an emergency plan would result in excessive costs compared to those of other facilities that are similarly situated. After the fuel is removed to the ISFSI and the reactor vesel and internals are removed from the 10 CFR 50 licensed area of the site, the remaining Trojan plant area, though licensed under 10 CFR 50, will be comparable to many source and byproduct licensees, in terms of the level of emergency preparedness needed to protect the public health and safety, where emergency plans are not required. As such, the continued application of 10 CFR 50 emergency plan requirements would force the Trojan facility to expend significantly more funds for emergency preparedness than other facilities similarly situated.

In light of movement of the spent nuclear fuel from the Trojan Plant to the ISFSI, removal of the reactor vessel and internals from the 10 CFR 50 licensed area of the site, and implementation of the 10 CFR 72 Trojan Independent Spent Fuel Storage Installation Emergency Plan (PGE-1075),

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. i VPN-014-98 Attachment I August 27,1998

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- PGE requests a license amendment, pursuant to 10 CFR 50.90, to delete the requirement to I I

establish, implement, and maintain written procedures covering defueled emergency plan implementation [ Technical Specification 5.7.1.1.f].

Attachment il provides a copy of the affected Technical Specification page with changes annotated, i

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3. No Significant IIazards Consideration Determination i In accordance with the requirements of 10 CFR 50.90, " Application for amendment oflicense or construction permit," this license amendment request is judged to involve no significant hazards based upon the following: a

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

The proposed elimination of the emergency plan requirements from the 10 CFR 50 license is predicated on completion of transfer of the spent nuclear fuel to the proposed  !

1 10 CFR 72 ISFSI licensed area and removal of the reactor vessel and internals from the 10 CFR 50 licensed area of the site. Removal of the potential radiological source terms for accidents previously evaluated effectively eliminates the credibility of the accidents, therefore, elimination of the emergency plan requirements does not involve a significant increase in the probability or consequences of an accident previously evaluated.  ;

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

i The proposed change is deletion of emergency plan requirements and, as such, has no I direct impact on plant equipment or the procedures for operating plant equipment.

Therefore, it does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

. safety.

Following the removal of the spent nuclear fuel and the reactor vessel and internals from the 10 CFR 50 licensed area, the remaining credible accidents are limited to decommissioning activities. The potential accidents associated with decommissioning

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VPN-014-98 Attachment I August 27,1998 Page 11 pf 11 activities are presented in the TNP Decommissioning Plan and have been shown to have consequences less than the EPA PAGs. Following the removal of the spent nuclear fuel and the reactor vessel (including the internals) from the 10 CFR 50 site, no credible accidents associated with the remaining decommissioning activities would require pre-planned emergency measures to avoid acute radiation doses. The deletion of the Trojan Nuclear Plant Permanently Defueled Emergency Plan will not result in a reduction in the margin of safety previously analyzed. Therefore, the proposed 10 CFR 50 license amendment does not involve a significant reduction in a margin of safety.

4. Schedule Consideration The removal of the reactor vessel and internals from the 10 CFR 50 licensed area is scheduled for completion prior to October 30,1999. The completion of the transfer of the spent nuclear fuel assemblies from the 10 CFR 50 licensed area to the pending 10 CFR 72 license ISFSI is scheduled for completion by February 20,2000. It is therefore requested that NRC approval be granted in October 1999, with an implementation date coincident with the completion of the transfer of spent nuclear fuel assemblies and reactor vessel and internals from the 10 CCR 50 licensed area. This will allow a minimum of 90 days to implement the administrative revisions required.

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Procedures, Programs,'and Manuals 5.7-A0 ADMINISTRATIVE CONTROLS 5.7 Procedures, Programs, and Manuals 5.7.1 Procedures 5.7.1.1 Scope Written procedures shall be established, implememed, and maintained covering the following activities:

a. The procedures applicable to the safe storage ofirradiated fuel recommended in Regulatory Guide 1.32, Revision 2, Appendix A, February 1978;

b. Defueled security plan implementation;

c. Intentionally deleted;Defuclcd caicrgcacy plan l in;picnica a;ica

d. Quality assurance for radiological effluent and environmental monitoring;

e. Fire protection program implementation; and

f. All programs speciSed in Specification 5.7.2. l 5.7.1.2 Review and Approval Each procedure of Specification 5.7.1.1, and changes thereto, shall be independently reviewed in accordance with established administrative procedures and approved by the Plant General Manager or his designee prior to implementation.

5.7.1.3 Temporary Changes Temporary changes to procedures of Specification 5.7.1.1 may be made provided:

a. The intent of the existing procedure is not altered;

b. The change is approved by a member of the facility management staff and by a CERTIFIED FUEL IIANDLER; and l

r TROJAN UNIT l- 5-15 A'MENDMENT NO. xxx l t

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