ML081400477

5/20/2008 J. R. Hall Ltr. to J. T. Conway Humboldt Bay Independent Spent Fuel Storage Installation Spent Fuel Characterization Issues

ML081400477
Person / Time
Site:	Humboldt Bay
Issue date:	05/20/2008
From:	Hall J NRC/NMSS/SFST
To:	Conway J Pacific Gas & Electric Co
References
TAC L24179
Download: ML081400477 (5)

Text

May 20, 2008 Mr. John T. Conway Site Vice President and Chief Nuclear Officer Pacific Gas and Electric Company P. O. Box 3 Mail Code 104/6/601 Avila Beach, CA 93424

SUBJECT:

HUMBOLDT BAY INDEPENDENT SPENT FUEL STORAGE INSTALLATION -

SPENT FUEL CHARACTERIZATION ISSUES

Dear Mr. Conway:

On November 17, 2005, the U.S. Nuclear Regulatory Commission (NRC) issued a site-specific license for the Humboldt Bay Independent Spent Fuel Storage Installation (ISFSI) to the Pacific Gas and Electric Company (PG&E), in accordance with 10 CFR Part 72. PG&E has completed construction of the ISFSI, and plans to commence the transfer of spent fuel from the Humboldt Bay Power Plant to the ISFSI in the near future. In preparing for the NRC inspections related to the ISFSI, NRC staff held discussions with your staff about the characterization of the Humboldt Bay spent fuel. Those discussions led to a public meeting on the subject, held at NRC headquarters in Rockville, Maryland, on February 5, 2008.

At that meeting, your staff described the inspection and evaluation methods used to characterize the Humboldt Bay fuel assemblies currently stored in the plants spent fuel pool as either intact or damaged, in accordance with the definitions presented in the Technical Specifications (TS) for the Humboldt Bay ISFSI license. The NRC staff considered the information provided by PG&E at the February 5 meeting and in several telephone discussions, and ultimately questioned the adequacy of your fuel characterization methods to justify your classification of intact fuel. The staffs primary concern was that PG&Es method appeared to rely solely on external video examinations of the spent fuel assemblies to classify assemblies as intact, and in the staffs judgment, such an approach is not sufficient by itself to confirm the absence of gross cladding breaches on the unobservable portions of the fuel rods.

By letter dated April 24, 2008, PG&E described its additional efforts to supplement the fuel video examinations, in support of your revised fuel classification program at Humboldt Bay. These additional efforts consisted of the identification, review and evaluation of plant operating records, including records of fuel sipping and off gas activity. The application of these additional fuel characterization methods resulted in a net increase in the total number of fuel assemblies classified as damaged, from 96 to 129, of the 390 assemblies in the spent fuel pool. PG&E concluded that the revised approach used, the assumptions made, and the conclusions reached are consistent with the Humboldt Bay ISFSI licensing basis, and that no further NRC licensing actions are required in order to proceed with fuel loading.

The NRC staff has reviewed the information in PG&Es letter of April 24, 2008, and concludes that the additional analyses of reactor operating records, in conjunction with the prior video

J. Conway examinations performed, constitute a reasonable approach to the classification of intact and damaged fuel at Humboldt Bay. The staff focused its review on the overall method employed and relied upon PG&Es application of the method for the analysis and classification of individual fuel assemblies. The staffs acceptance of this method at Humboldt Bay does not imply that the same method and assumptions are necessarily appropriate for application at another site. The general guidance provided in NRC Interim Staff Guidance Document No. 1, Revision 2 (ISG-1) regarding damaged fuel should be considered by licensees in developing fuel characterization programs for their sites, with respect to dry cask storage activities.

If you have any questions on these matters, please contact me at (301) 492-3319.

Sincerely,

/RA/

James R. Hall, Senior Project Manager Licensing Branch Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards Docket No. 72-27 TAC No. L24179 cc: Humboldt Bay Service List

J. Conway examinations performed, constitute a reasonable approach to the classification of intact and damaged fuel at Humboldt Bay. The staff focused its review on the overall method employed and relied upon PG&Es application of the method for the analysis and classification of individual fuel assemblies. The staffs acceptance of this method at Humboldt Bay does not imply that the same method and assumptions are necessarily appropriate for application at another site. The general guidance provided in NRC Interim Staff Guidance Document No. 1, Revision 2 (ISG-1) regarding damaged fuel should be considered by licensees in developing fuel characterization programs for their sites, with respect to dry cask storage activities.

If you have any questions on these matters, please contact me at (301) 492-3319.

Sincerely,

/RA/

James R. Hall, Senior Project Manager Licensing Branch Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards Docket No. 72-27 TAC No. L24179 cc: Humboldt Bay Service List DISTRIBUTION:

SFST r/f BWhite NMamish EHackett MBailey DPstrak LCampbell BSpitzberg, RIV RKellar, RIV MWaters JHickman, FSME APessin, OGC AMendiola, NRR ML081400477 OFC: SFST SFST SFST SFST SFST NAME: JRHall WWheatley REinziger CRegan MRahimi DATE: 05/09/08 05/19/08 05/19/08 05/19/08 05/20/08 C = COVER E = COVER & ENCLOSURE N = NO COPY

Humboldt Bay Service List cc:

Redwood Alliance Mr. John T. Conway P.O. Box 293 Site Vice President and Arcata, CA 95521 Chief Nuclear Officer Pacific Gas and Electric Company Dr. Rich Ferguson, Energy Chair P. O. Box 3 Sierra Club California Mail Code 104/6/601 1100 11th Street, Suite 311 Avila Beach, CA 93424 Sacramento, CA 94814 James Becker Mr. Gary Butner, Acting Radiation Program Vice President - Diablo Canyon Operations Director and Station Director Radiologic Health Branch Diablo Canyon Power Plant Dept. of Health Services, MS-7610 PO Box 56 PO Box 997414 Avila Beach, CA 93424 Sacramento, CA 95899-7414 Loren Sharp, Director and Plant Stephen Hsu, M.S., Senior Health Physicist Manager, Humboldt Bay Nuclear Radiological Assessment Unit Pacific Gas & Electric Company Radioactive Material Licensing Section 1000 King Salmon Avenue Radiologic Health Branch Eureka, CA 95503 Dept. of Health Services, MS-7610 PO Box 997414 Jennifer K. Post Sacramento, CA 95899-7414 Law Department Pacific Gas and Electric Company Commissioner 77 Beale Street, B30A California Energy Commission San Francisco, CA 1516 Ninth Street Sacramento, CA 95814 Chairman, Humboldt County Board of Supervisors Deputy Attorney General County Courthouse State of California 825 Fifth Street 110 West A Street, Suite 700 Eureka, CA 95501 San Diego, CA 92101 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 California Public Utilities Commission 505 Van Ness, Room 4102 San Francisco, CA 94102 California Public Utilities Commission 505 Van Ness, Room 4102 San Francisco, CA 94102