HBL-18-019, Summary of Changes to the Humboldt Bay Emergency Plan (Revision 9)
| ML18353B039 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 12/19/2018 |
| From: | Welsch J Pacific Gas & Electric Co |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| HBL-18-019, HIL-18-010 | |
| Download: ML18353B039 (14) | |
Text
Pacific Gas and Electric Company" James M. Welsch Diablo Canyon Power Plant Vice President P.O. Box 56 Nuclear Generation and Avila Beach, CA 93424 Chief Nuclear Officer 805.545.3242 E-Mail: James.Welsch@pge.com December 19, 2018 10 CFR 50.54 PG&E Letter HBL-18-019 10 CFR 72.44 PG&E Letter HIL-18-010 ATTN: Document Control Desk Director, Division of Spent Fuel Storage and Transportation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Docket No. 50-133, License No. DPR-7 Humboldt Bay Power Plant, Unit 3 Docket No. 72-27, Materials License No. SNM-2514 Humboldt Bay Independent Spent Fuel Storage Installation Summary of Changes to the Humboldt Bay Emergency Plan (Revision 9)
Dear Commissioners and Staff:
Pursuant to 10 CFR 50.4, 10 CFR 50.54(q), 10 CFR 72.4, and 10 CFR 72.44(f),
Pacific Gas and Electric Company (PG&E) hereby submits the attached summary of the analysis of changes incorporated into HBI-L4, Humboldt Bay Emergency Plan, Revision 9 (Plan), which became effective November 27, 2018. These changes did not decrease the effectiveness of the Plan, and the Plan continues to meet the requirements of 10 CFR 50.47(b), 10 CFR 50 Appendix E, and 10 CFR 72.32(a).
This submittal does not contain privacy and proprietary information identified in accordance with NRC Generic Letter 81-27, "Privacy and Proprietary Material in Emergency Plans."
PG&E makes no new or revised regulatory commitments (as defined by NEI 99-04) in this letter.
If there are questions regarding this submittal, please contact Mr. Lewis Mayfield, ISFSI Manager at (707) 444-0784.
Sincerely,
~~~
James M. Welsch Enclosure
m Document Control Desk December 19, 2018 Page 2 PG&E Letter HBL-18-019 PG&E Letter HIL-18-010 cc: Humboldt Distribution cc/enc: William C. Allen, NMSS Project Manager John B. Hickman, NRC Project Manager Kriss M. Kennedy, NRC Region IV Administrator
Enclosure 1 PG&E Letter HBL-18-019 PG&E Letter HIL-18-010 Summary of the Analysis of Changes to HBI-L4, Humboldt Bay Emergency Plan, Revision 9
Enclosure-1 PG&E Letter HBL-18-019 PG&E Letter HIL-18-010 Summary of the Analysis of Changes to HBI-L4! Revision 9_,_ "Humboldt Bay Emergency Plan" Original Content Content Change Reason for Change Change #1-Section 2.1, Site Description (Paragraph one): Updated site description to reflect current site conditions and changes due to decommissioning.
The Humboldt Bay Power Plant site includes a The Humboldt Bay Power Plant site includes a single, non-operational nuclear unit (Unit 3) nuclear unit (Unit 3) in the final phases of D&D This change does not affect how the current undergoing D&D and the HB ISFSI. and license termination and the HB ISFSI. Emergency Plan (E-Plan) meets any planning Necessary support structures, equipment, and standards, elements, or site-specific tanks are also located on the site. commitments. No additional evaluation required .
Change #2-Section 2.1, Site Description (Paragraph During the major phases of decommissioning, an three) : interface procedure existed between the Humboldt An interface desk guide is in place to describe Bay Power Plant (HBPP)/Humboldt Bay Independent An interface procedure is in place to describe how HB ISFSI and HBGS coordinate responses to Spent Fuel Storage Installation (ISFSI) and the how HBPP and HBGS coordinate responses to emergency situations. Humboldt Bay Generating Station (HBGS) . When emergency situations. closer coordination was no longer needed, the procedure was superseded by an agreement, in the form of a desk guide, between Humboldt Bay ISFSI and the HBGS. Humboldt Bay ISFSI and HBGS staffs are responsible for command and control responsibilities at their respective sites. The desk guide describes coordinated responses to shared emergency situations. Humboldt Bay ISFSI Emergency Plan Implementing Procedures also contain steps to notify HBGS during emergency situations .
This change does not affect how the current E-Plan meets any planning standards, elements, or site-specific commitments. No additional evaluation required.
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Enclosure-1 PG&E Letter HBL-18-019 PG&E Letter HIL-18-010 Summary of the Analysis of Changes to HBI-L4~~evlsion 9, "Hul'l!boldt Bay Emergency Plan" Original Content Content Change Reason for Change Section 2.3, Licensed Site Description - Section 2.3, Licensed Site Description - Section Change #3-Section 2.3 .1, HBPP Unit 3: 2.3 .1, HBPP Unit 3: Updated Licensed Site Description section for Unit 3 to reflect current site conditions and changes due to Note: The following description of HBPP Unit 3 HBPP Unit 3 is in the final stages of D&D with decommissioning.
is subject to change as D&D activities focus on final surveys as required by the License progress. Termination Plan and Final Site Restoration This change does not affect how the current E-activities for site closure. Plan meets any planning standards, elements, or HBPP Unit 3 has been shut down since July site-specific commitments. No additional 1976. Although the remaining radioactive evaluation required.
source term for an accidental release at the defueled Unit 3 reactor site has been greatly reduced by radioactive decay and spent fuel removal, there still exists radioactively contaminated structures requiring demolition.
Due to the internal hazard risk to workers of transuranic contamination, administrative and engineering controls will be used during D&D activities to limit hazards to the workers.
These controls will also limit potential off-site doses to considerably less than the EPA 400 protective action guide limit of 1 rem .
The drywell and suppression chamber are located within a reinforced concrete caisson that is located entirely below grade. The caisson is approximately 18 m (60 feet) in diameter with an inside depth of 24 m (78 feet) below grade. A caisson access shaft extends from the top of the caisson to the space beneath the drywell Page 2 of 11
Enclosure-1 PG&E Letter HBL-18-019 PG&E Letter HIL-18-010 Summary of the Analysis of Changes to HBI-L4, Revision 9, "Humboldt Bay Emergency Plan" Original Content Content Change Reason for Chan_g_e Section 2.3.2, HB ISFSI , paragraph two, last Change #4-sentence: The fence that surrounds the ISFSI vault structure is referred to as the "Security Area Fence" in the A Security Area and a Restricted Area fence, A Security Area fence, with a locked gate, Humboldt Bay ISFSI Final Safety Analysis Report with a locked gate, surrounds the vault surrounds the vault structure. (FSAR). The Humboldt Bay ISFSI has a protected structure. area located inside the Security Area, but under the ISFSI vault lids and is inaccessible to personnel.
A fence , with a locked gate, surrounds the vault structure.
This change does not affect how the current E-Plan meets any planning standards, elements, or site-specific commitments. No additional evaluation required.
Figure 2.1-1, Humboldt Bay Site Map was Figure 2.1-1, Humboldt Bay Site Map was Change #5-outdated due to decommissioning. replaced with a current map. Updated site map to show current site conditions.
Changes are due to decommissioning.
This change does not affect how the current E-Plan meets any planning standards, elements, or site-specific commitments. No additional evaluation re_g_uired.
Figure 2.1-1 , Humboldt Bay Site Layout - Figure 2.1-1, Humboldt Bay Site Layout - Building Change #6-Building List was outdated due to List was also updated to reflect changes to site Figure 2.1-1 , Humboldt Bay Site Layout - Building decommissioning. buildings due to decommissioning. List was updated to reflect changes made to site due to decommissioning.
This change does not affect how the current E-Plan meets any planning standards, elements, or site-specific commitments. No additional evaluation required.
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Enclosure-1 PG&E Letter H B L-18-019 PG&E Letter HIL-18-010 Summary of the Anal1 sis of Changes to HBI-L4, Revision 9, "Humboldt Bay Emergency Plan" Original Content Content Change Reason for Change Section 3.0, Emergency Conditions, paragraph Change #7-two: The interface procedure between the Emergency conditions impacting the Humboldt HBPP/Humboldt Bay ISFSI and the HBGS has been Emergency conditions impacting the Humboldt Bay Generating Station are addressed in a superseded by an agreement between Humboldt Bay Bay Generating Station are addressed in a HBPP/HBGS site interface desk guide and ISFSI and the HBGS in the form of a desk guide.
HBPP/HBGS site interface procedure and appropriate Emergency Plan Implementing appropriate Emergency Plan Implementing Procedures. This change does not affect how the current E-Procedures. Plan meets any planning standards, elements, or site-specific commitments. No additional evaluation required.
Section 3.2, Postulated Emergency Conditions Change#8-(Paragraph one) : Updated Postulated Emergency Conditions section Radioactive material at HBPP Unit 3 is limited Radioactive material at HBPP Unit 3 is limited to to reflect current site radiological conditions changes primarily to surface contamination from residual contamination from previous plant due to decommissioning activity.
previous plant operations. Due to the internal operations. Administrative and engineering hazard risk to workers from transuranic controls are used during D&D activities to protect This change does not affect how the current E-contamination, administrative and engineering workers. Plan meets any planning standards, elements, or controls are used during D&D activities to site-specific commitments. No additional protect workers and the public from airborne evaluation required .
releases.
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Enclosure-1 PG&E Letter HBL-18-019 PG&E Letter HIL-18-010 Summary of the Analysis of Changes to HBI-L4, Revision 9, "Humboldt Bay Emergency Plan" Original Content Content Change Reason for Change Section 3.2, Postulated Emergency Conditions Change #9-(Paragraph four) : Updated Postulated Emergency Conditions section to reflect current site radiological conditions changes Under bounding conditions and without the There are no credible accidents in Unit 3 that due to decommissioning activity.
implementation of controls described could result in the release of radioactive materials previously, there are no postulated accidents in to the environment in quantities that could require This change does not affect how the current E-Unit 3 that could result in the release of the implementation of protective actions for the Plan meets any planning standards, elements, or radioactive materials to the environment in general public. There are no postulated accidents site-specific commitments. No additional quantities that could require the for the HB ISFSI that could result in the release of evaluation required.
implementation of protective actions for the radioactive materials to the environment in general public. As stated earlier, due to the quantities that would require the implementation necessary worker controls to limit internal of protective actions for the general public.
doses, these accidents are not considered Therefore, no response by federal, state, or local credible. There are no postulated accidents for agencies is required for radiological releases.
the HB ISFSI that could result in the release of radioactive materials to the environment in quantities that would require the implementation of protective actions for the general public. Therefore, no response by federal, state, or local agencies is required for radiological releases .
Section 3.2.1 .1, Damage to a Loaded Cask, Change #10-Detection (Paragraph two, Sentence three): Sentence reworded to provide clarification .
Detection: Detection : This change does not affect how the current E-Routine radiological surveys provide Routine radiological surveys provide Plan meets any planning standards, elements, or baseline information regarding the expected baseline information regarding the expected site-specific commitments. No additional radiological status, familiarity with radiological radiological status . Familiarity with radiological evaluation required.
survey equipment use by the ISFSI staff, and survey equipment used by the ISFSI staff heightens sensitivity to an anomalous condition heightens sensitivity to an anomalous condition above or below the initiating condition above or below the initiating condition threshold.
threshold.
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Enclosure-1 PG&E Letter HBL-18-019 PG&E Letter HIL-18-010 Summary of the Analysis of Changes to HBI-L4, Revision 9, "Humboldt Bay Emergency Plan" Original Content Content Change Reason for Change Section 3.3, Hazardous Chemicals: Change #11-10 CFR 72 .32(a)(13) refers to the Emergency 10 CFR 72.32(a)(13) refers to the Emergency Planning and Community Right-to-Act of 1986, Planning and Community Right-to-Act of 1986, Provided additional information related to the Title Ill. Pub. L.99-499 (EPCRA), with respect Title Ill. Pub. L.99-499 (EPCRA), with respect to contents of the Hazardous Materials Business Plan.
to hazardous materials at the ISFSI. EPCRA hazardous materials at the ISFSI. EPCRA stipulates that, if a facility has an extremely stipulates that, if a facility has an extremely Clarified information related to filing the Hazardous hazardous substance in an amount greater hazardous substance in an amount greater than Materials Business Plan with the Humboldt County than the appropriate threshold planning the appropriate threshold planning quantity, then Environmental Health Agency.
quantity, then the facility must designate a the facility must designate a facility Emergency facility Emergency Coordinator to participate in Coordinator to participate in the local planning This change does not affect how the current E-the local planning process. The ISFSI does process. The ISFSI does not have extremely Plan meets any planning standards, elements, or not have extremely hazardous substances hazardous substances present in amounts equal site-specific commitments. No additional present in amounts equal to or greater than the to or greater than the threshold planning evaluation required.
threshold planning quantities of 40 CFR 355 quantities of 40 CFR 355 Appendix A within the Appendix A within the EPA's Code of Federal EPA's Code of Federal Regulations. The Regulations . Therefore, the Emergency Hazardous Materials Business Plan for the facility Coordinator is not required to participate in the includes necessary information on hazardous local planning process . materials for the site. Therefore, the Emergency 40 CFR 302.4, Appendix B, lists radioactive Coordinator is not required to participate in the material as a hazardous substance. California local planning process .
State law (Health and Safety Code 25500) requires that this material be listed in the facility Hazardous Materials Business Plan filed with the local agency (Humboldt County Environmental Health). Because limited quantities of other hazardous materials are stored and used at the ISFSI and Unit 3, spills or other accidents involving other hazardous materials do not have the potential for posing a threat to onsite or offsite personnel and would not constitute an emergency condition.
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Enclosure-1 PG&E Letter HBL-18-019 PG&E Letter HIL-18-010 Summary of the Anal 11 sis of Changes to HBI-L4, Revision 9, "Humboldt Bay Emergency Plan" Original Content Content Change Reason for Change 40 CFR 302.4, Appendix B, lists radioactive material as a hazardous substance. California State law (Health and Safety Code 25500) requires that this material be listed in the facility Hazardous Materials Business Plan which is filed with the local agency (Humboldt County Environmental Health) and confirms the site's compliance with the EPCRA. Because limited quantities of other hazardous materials are stored and used at the ISFSI and Unit 3, spills or other accidents involving other hazardous materials do not have the potential for posing a threat to onsite or offsite personnel and would not constitute an emerqencv condition .
Sections 4.2.1, 4.2.2, 4.2 .3, 5.1 .2, 6.1, 8.2.2: Sections 4.2.1, 4.2 .2, 4.2.3, 5.1.2, 6.1, 8.2.2 : Change #12-Humboldt County Sheriff's Department Changed the title of the "Humboldt County Sheriff's Office is the correct title for the agency and Sheriff's Department" to "Humboldt County is now consistent throughout this document and Sheriff's Office." related Emergency Plan Implementing Procedures.
This change does not affect how the current E-Plan meets any planning standards, elements, or site-specific commitments. No additional evaluation required.
Section 5.1.1.4, Notification of personnel Change #13-assigned to the Humboldt Bay Generating The interface procedure between the Station : HBPP/Humboldt Bay ISFSI and the HBGS has been An interface desk guide and emergency plan superseded by an agreement between Humboldt Bay Interface procedures (HBPP and HBGS) are in implementing procedures are in place to address ISFSI and the HBGS in the form of a desk guide.
place to address the notification process for the notification process for events impacting events impactinq HBGS. HBGS.
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Enclosure-1 PG&E Letter HBL-18-019 PG&E Letter HIL-18-010 Summary _of the Analysis of Changes to HBI-L4, Revision 9, "Humboldt Bay Emergency Plan" Orig_inal Content Content Chan_g_e Reason for Change ISFSI Emergency Plan Implementing Procedures also contain steps to notify HBGS during emergency situations.
This change does not affect how the current E-Plan meets any planning standards, elements, or site-specific commitments. No additional evaluation re_g_uired.
Section 5.3.1 .5, Assembly/Evacuation of Change #14-Humboldt Bay Generating Station: The interface procedure between the An interface desk guide and emergency plan HBPP/Humboldt Bay ISFSI and the HBGS has been Interface procedures (HBPP and HBGS) are in implementing procedures are in place to address superseded by an agreement between Humboldt Bay place to address the assembly and evacuation the assembly and evacuation of HBGS personnel. ISFSI and the HBGS in the form of a desk guide.
of HBGS personnel. ISFSI Emergency Plan Implementing Procedures also contain steps to notify HBGS during emergency situations.
This change does not affect how the current E-Plan meets any planning standards, elements, or site-specific commitments. No additional evaluation required.
Section 8.3.2 Exercises (Paragraph one) : Change #15-The E-Plan section on Exercises was silent on the An exercise is an event testing the integrated An exercise is an event testing the integrated regulatory requirement on exercise scenarios not capability, and a major portion of the basic capability, and a major portion of the basic known to most exercise participants.
elements, existing within emergency elements , existing within emergency preparedness plans and organizations. preparedness plans and organizations . Exercise scenarios used are not known to most participants .
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Enclosure-1 PG&E Letter HBL-18-019 PG&E Letter HIL-18-010 Summary of the Analysis of Changes to HBI-L4, Revision 9, "Humboldt Bay Emergency Plan" Orig_inal Content Content Change Reason for Change Addition of this language regarding exercise scenarios not being known to most exercise participants, aligns the E-Plan with the current Humboldt Bay ISFSI Emergency Plan Implementing Procedures and regulatory requirements.
This change does not affect how the current E-Plan meets any planning standards, elements, or site-specific commitments. No additional evaluation required.
Section 8.3 .2 Exercises (Paragraph seven): Change #16-Following an exercise, observers and principal Following an exercise, observers and principal The E-Plan section on Exercises was silent on the participants critique the event and the results participants critique the event and the results are regulatory requirement on exercise critiques .
are presented for review and approval under a presented for review and approval under a designated management review process. Any designated management review process . The Addition of this language regarding exercise scenario weaknesses or deficiencies that are identified critique is conducted as part of each exercise to critiques, aligns the E-Plan with the current Humboldt in a critique of an exercise, a drill or for training evaluate the appropriateness of the plan , Bay ISFSI Emergency Plan Implementing must be corrected. emergency procedures, facilities, equipment, Procedures and regulatory requirements .
training of personnel, and overall effectiveness of the response . Any weaknesses or deficiencies This change does not affect how the current E-that are identified in a critique of an exercise, a Plan meets any planning standards, elements, or drill or for training must be corrected . site-specific commitments. No additional evaluation re_g_uired.
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Enclosure-1 PG&E Letter HBL-18-019 PG&E Letter HIL-18-010 Summary of the Analysis of Changes to HBI-L4, Revision 9, "Humboldt Bay Emergency Plan" Original Content Content Change Reason for Change Definitions section of Appendix A - Definitions , Change #17-abbreviations and acronyms : The definition of "facility" was removed from the list of definitions to avoid potential inconsistencies with the Facility - Refers to HBPP Unit 3 plant being I Removed use of the term elsewhere in the Emergency Plan .
decommissioned.
This change does not affect how the current E-Plan meets any planning standards, elements, or site-specific commitments. No additional evaluation required.
Definitions section of Appendix A - Definitions, Change #18-abbreviations and acronyms : These definitions were removed as they are no Definitions: longer mentioned in the E-Plan .
Derived Air Concentration - As defined by 10 I Removed CFR 20.1 003. This change does not affect how the current E-Plan meets any planning standards, elements, or Restricted Area - An area to which access is site-specific commitments. No additional limited for the purpose of protecting individuals I Removed evaluation required.
against undue risks from exposure to radiation and radioactive materials.
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Enclosure-1 PG&E Letter HBL-18-019 PG&E Letter HI L-18-01 0 Summary of the Analysis of Changes to HBI-L4, Revision 9, "Humboldt Bay Emergency Plan" Original Content Content Change Reason for Change Definitions section of Appendix A - Change#19-Definitions, abbreviations and acronyms: MLLW is referenced in Section 2.0 and was added to the list of Abbreviations and Acronyms in Appendix A Abbreviations/Acronyms added . I MLLW- Mean Lower Low Water for completeness .
This change does not affect how the current E-Plan meets any planning standards, elements, or site-specific commitments. No additional evaluation required.
Definitions section of Appendix A - Change #20-Definitions, abbreviations and acronyms: These definitions were removed as they are no longer mentioned in the E-Plan and no longer Abbreviations and Acronyms: applicable due to decommissioning .
ALARA -As Low As Reasonably I All removed.
This change does not affect how the current E-Achievable Plan meets any planning standards, elements, or Ci - Curie site-specific commitments. No additional DAC - Derived Air Concentration evaluation required.
GM - Geiger-Mueller Radiation Monitor m - meter ODCM - Offsite Dose Calculation Manual MSL - Mean Sea Level PA - Protected Area PSRC - Plant Staff Review Committee RFB - Refueling Building RMS - Records Management System SAFSTOR - Custodial Storage of Unit 3 Prior to Dismantlement TEDE - Total Effective Dose Equivalent TLD - Thermoluminescent Dosimeter J:J_Ci/cc - Microcuries per Cubic Centimeter Page 11 of 11