HBL-85-059, Forwards Rev 1 to Humboldt Bay Power Plant Unit 3 - Safstor QA Plan, Replacing Attachment 4 of 840731 Decommissioning Plan.Basis for & Description of Approach Included

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Forwards Rev 1 to Humboldt Bay Power Plant Unit 3 - Safstor QA Plan, Replacing Attachment 4 of 840731 Decommissioning Plan.Basis for & Description of Approach Included
ML20138L837
Person / Time
Site: Humboldt Bay
Issue date: 12/13/1985
From: Shiffer J
PACIFIC GAS & ELECTRIC CO.
To: Berkow H
Office of Nuclear Reactor Regulation
Shared Package
ML20138L840 List:
References
HBL-85-059, HBL-85-59, NUDOCS 8512200066
Download: ML20138L837 (4)


Text

l PACIFIC G-A S AND E LE C T RIC C O M PANY IENb/d b l 77 DE/ tJTREET . SAN FRANCISCO, CALIFORNIA 94106 * (415)781-4211 . TWX 910-3 72-6587 iJ AMES D. SHIPPER VKs PetMMNT mu.'*'"""'*" December 13, 1985 PGandE Letter No.: HBL-85-059 Mr. Herbert N. Berkow, Director Standardization and Special Projects Directorate Division of PWR Licensing-B U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: Docket No. 50-133, OL-DPR-7 Humboldt Bay Power Plant, Unit No. 3 '

Custodial SAFSTOR Facility Quality Assurance Plan, Revision 1

Dear Mr. Berkow:

Enclosed is Revision 1 to the SAFSTOR Quality Assurance Plan (Plan) for Humboldt Bay Power Plant, Unit 3 (HBPP-3). This revision replaces Attachment 4 of the HBPP-3 Decommissioning Plan, dated July 1984.

PGandE has reevaluated the scope of the Plan relative to the applicable NRC regulatory requirements for activities to be conducted during the HBPP-3 SAFSTOR period and determined that the Plan should be revised. PGandE has concluded that rather than apply a general, full-scale plan, a graded approach commensurate with the nature of the HBPP-3 SAFSTOR activities is more appropriate. The basis for this conclusion and a description of the approach taken are presented in Attachment A.

Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope.

Sincerely,

. . hiffer Enclosures cc: P. B. Erickson (2)

J. B. Martin Humboldt Distribution \

Service List (Decommissioning) h0 1 0630S/0038K/GHM/1739 8512200066 851213 PDR ADOCK 05000133 P PDR ,

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ATTACHMENT A HBPP-3 SAFSTOR QUALITY ASSURANCE PLAN (REVISION 1):

BASIS FOR APPROACH

1.0 INTRODUCTION

HBPP-3 SAFSTOR activities are described in Sections 5 and 6 of the SAFSTOR Decommissioning Plan submitted in July 1984. These activities will be conducted in accordance with applicable NRC regulations.

In order to determine requirements for the SAFSTOR Quality Assurance Plan, regulations applicable to those activities anticipated during SAFSTOR were reviewed to identify quality assurance requirements. Regulations and Regulatory Guides which required quality assurance plans, and could potentially affect SAFSTOR activities, are:

(a) 10CFR50, Appendix B. " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants".

(b) 10CFR71, " Packaging and Transportation of Radioactive Material".

(c) U.S. Nuclear Regulatory Commission (USNRC) Regulatory Guide 4.15. " Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment".

The applicability to HBPP-3 SAFSTOR activities of each of these regulations or regulatory guidance and the plan approach are described below.

2.0 APPLICABILITY OF 10CFR50. APPENDIX B The gaality assurance measures contained in 10CFR50, Appendix B apply to safety-related components, systems, and structures, i.e., those components, systems, and structures needed to prevent or mitigate the radiological consequences of credible accidents to less than the limits of 10CFR100.

Thus, the applicability of 10CFR50, Appendix B to HBPP-3 SAFSTOR operations depends upon whether the HBPP-3 components, systems, and structures need to be classified and treated as safety-related.

As discussed in Appendix I to the HBPP-3 SAFSTOR Decommissioning Plan and in Section 6.3 of the HBPP-3 SAFSTOR Environmental Report, potential accidents during the SAFSTOR period have a low probability and are few in number.

Analyses of potential accidents, assuming' worse-case conditions, demonstrate that the HBPP-3 components, systems, and structures need not function to prevent or mitigate the radiological consequences to less than 10CFR100 limits. Thus, the components, systems, and structures need not be classified as safety-related and thus are not subject to 10CFR50, Appendix B quality assurance measures.

3.0 APPLICABILITY OF 10CFR71 Containers may be used to transport radioactive materials during the HBPP-3 SAFSTOR period. Thus, the quality assurance requirements of 10CFR71.101 would be applicable for this activity.

4.0 APPLICABILITY OF REGULATORY GUIDE 4.15 Radiological monitoring of gaseous and liquid effluents and the environment will be conducted in accordance with the HBPP-3 Technical Specifications. While the level of radioactivity to be potentially released during SAFSTOR operations is well within regulatory limits, it is still important to assure that the radiological monitoring measurements are valid. Thus, the quality assurance requirements of Regulatory Guide 4.15 are deemed applicable.

5.0 PLAN APPROACH The Plan first describes the quality assurance organization responsible for implementing the Plan. General quality assurance requirements common to the activities covered by the Plan are then described.

These requirements include:

a. Procedures, Instructions, and Drawings.
b. Document Control.
c. Nonconformance Control.
d. Indoctrination and Training.
e. Records.
f. Audits.

With respect to the radiological monitoring of gaseous and liquid effluents, the plan requires compliance with USNRC Regulatory Guide 4.15 (Revision O, December 1977).

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Since shipments of radioactive wastes will be an infrequent evolution during the SAFSTOR period, the Plan requires compliance with the applicable requirements of the Diablo Canyon Power Plant Quality Assurance Program for this activity when it occurs. This approach will ensure that current quality assurance practices will be imposed at the time that activity is performed.

Although not required by a specific regulation or Regulatory Guide, the Plan will also include provisions for assuring that the requirements of the HBPP-3 Technical Specifications are implemented.