ML15007A433
| ML15007A433 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 01/14/2015 |
| From: | John Hickman Reactor Decommissioning Branch |
| To: | Halpin E Pacific Gas & Electric Co |
| References | |
| Download: ML15007A433 (8) | |
Text
January 14, 2015 Mr. Edward D. Halpin Senior Vice President and Chief Nuclear Officer Pacific Gas and Electric Company P.O. Box 56 Mail Code 104/6 Avila Beach, CA 93424
SUBJECT:
HUMBOLDT BAY POWER PLANT UNIT 3 - REQUEST FOR NRC APPROVAL OF LICENSE AMENDMENT REQUEST FOR PROPOSED REVISION TO HUMBOLDT BAY SITE EMERGENCY PLAN
Dear Mr. Halpin:
By letter dated June 30, 2014 (Agency-wide Documents Access and Management System (ADAMS) Accession No. ML14182A476), Pacific Gas and Electric Company (PG&E) requested a license amendment as required by Section 54(q)(ii)(4) to Title 10 of the Code of Federal Regulations of Part 50 for the Humboldt Bay Site (HB) Emergency Plan. Specifically, PG&E requested the NRCs review and approval of changes to the HB Emergency Plan. Our review has identified several items for which we will require more information prior to approval. The attached Request for Additional Information provides more specifics on the information needed.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
Sincerely,
/RA/
John B. Hickman, Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Docket No. 50-133 cc w/enclosure: Humboldt Bay Service List
Mr. Edward D. Halpin Senior Vice President and Chief Nuclear Officer Pacific Gas and Electric Company P.O. Box 56 Mail Code 104/6 Avila Beach, CA 93424
SUBJECT:
HUMBOLDT BAY POWER PLANT UNIT 3 - REQUEST FOR NRC APPROVAL OF LICENSE AMENDMENT REQUEST FOR PROPOSED REVISION TO HUMBOLDT BAY SITE EMERGENCY PLAN
Dear Mr. Halpin:
By letter dated June 30, 2014 (Agency-wide Documents Access and Management System (ADAMS) Accession No. ML14182A476), Pacific Gas and Electric Company (PG&E) requested a license amendment as required by Section 54(q)(ii)(4) to Title 10 of the Code of Federal Regulations of Part 50 for the Humboldt Bay Site (HB) Emergency Plan. Specifically, PG&E requested the NRCs review and approval of changes to the HB Emergency Plan. Our review has identified several items for which we will require more information prior to approval. The attached Request for Additional Information provides more specifics on the information needed.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
Sincerely,
/RA/
John B. Hickman, Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Docket No. 50-133 cc w/enclosure: Humboldt Bay Service List DISTRIBUTION: DCD r/f OGC ACRS/ACNW RKellar, RIV ML15007A433 OFFICE DWUP DWUP DWUP DWUP NAME JHickman CHolston BWatson JHickman 1/ 7 / 2015 1/ 12 / 2015 1/ 14 / 2015 1/14/ 2015 DATE OFFICIAL RECORD COPY
Humboldt Bay Power Plant, Unit 3 Service List cc:
Mr. Edward D. Halpin Mr. Gonzalo Perez, Radiation Program Senior Vice President and Director Chief Nuclear Officer Radiologic Health Branch Pacific Gas and Electric Company Dept. of Health Services, MS-7610 P.O. Box 56 P.O. Box 997414 Mail Code 104/6 Sacramento, CA 95899-7414 Avila Beach, CA 93424 Stephen Hsu, M.S., Senior Health Physicist Loren Sharp Radiological Assessment Unit Director and Plant Manager Radioactive Material Licensing Section Humboldt Bay Nuclear Radiologic Health Branch Pacific Gas & Electric Company Dept. of Health Services, MS-7610 1000 King Salmon Avenue P.O. Box 997414 Eureka, CA 95503 Sacramento, CA 95899-7414 Jennifer K. Post Commissioner Law Department California Energy Commission Pacific Gas and Electric Company 1516 Ninth Street 77 Beale Street, B30A Sacramento, CA 95814 San Francisco, CA Deputy Attorney General Chairman, Humboldt County Board State of California of Supervisors 110 West A Street, Suite 700 County Courthouse San Diego, CA 92101 825 Fifth Street Eureka, CA 95501 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 Redwood Alliance P.O. Box 293 Arcata, CA 95521 Dr. Rich Ferguson, Energy Chair Sierra Club California 1100 11th Street, Suite 311 Sacramento, CA 94814
REQUEST FOR ADDITIONAL INFORMATION HUMBOLDT BAY SITE LICENSE AMENDMENT REQUEST DOCKET NOS. 50-133 and 72-027 TAC J50319 By letter dated June 30, 2014 (Agency-wide Documents Access and Management System (ADAMS) Accession No. ML14182A476), Pacific Gas and Electric Company (PG&E) requested a license amendment as required by Section 54(q)(ii)(4) to Title 10 of the Code of Federal Regulations (10 CFR) of Part 50 for the Humboldt Bay Site (HB) Emergency Plan. Specifically, PG&E requested the NRCs review and approval of changes to the HB Emergency Plan.
The following draft requests for additional information (RAIs) are required to facilitate the technical review being conducted by the Office of Nuclear Security and Incident Response, Division of Preparedness and Response, Operating Reactor Licensing and Outreach Branch staff:
RAI-HB-01
- Enclosure 1, Section 2.0, Site, Area, and Facility Description, states (in part):
These changes also discuss administrative controls to limit source term and mitigation of radiological consequences of accidents.
- Enclosure 2, Page 1 of 14, states (in part):
Modular HEPA ventilation systems remain available for localized ventilation control and worker protection, but there is insufficient radiological source term to generate airborne effluents exceeding offsite dose calculation manual (ODCM) Specification limits.
- Enclosure 3, Section 2.3.1, HBPP Unit 3, provides (in part):
These controls will also limit potential off-site doses to considerably less than the EPA 400 protective action guide limit of 1 rem.
- Enclosure 4, Page 7 of 39, states (in part):
These controls will also limit potential off-site doses to considerably less than the EPA 400 Protective Action Guide limit of 1 rem.
What analyses have been performed to document that there is insufficient radiological source term to generate airborne effluents exceeding ODCM Specification limits as well as emergency action levels for effluent releases?
RAI-HB-02
- Enclosure 3, Section 3.1.1, Definitions, states (in part):
An Alert is defined as: Events are in process or have occurred which indicate a potential degradation of the level of safety at the facility or indicate a security threat to site protection. No releases of radioactive material requiring offsite response or monitoring are expected.
This definition of an Alert is not consistent with the guidance provided in Spent Fuel Project Office Interim Staff Guidance - 16, Emergency Planning, NEI 99-01 or NUREG-0654/FEMA-REP-1. Please provide justification for the definition as written or revise it to adhere to the guidance.
RAI-HB-03
- Enclosure 1, Section 3.0, Emergency Conditions, states (in part):
Emergency action levels (EALs) associated with HBPP were removed and ISFSI EALs were changed using the guidance of NEI 99-01, Revision 6.
- Enclosure 2, Page 7 of 14, states (in part):
It is acknowledged that a scenario could exist where a security event, earthquake, tornado or tsunami may serve as the motive force to create a radiological event and prohibit implementation of administrative controls. In that case, the radiological issues become secondary. No radiological emergency response actions would be implemented without extreme danger to the emergency response teams.
- Enclosure 3, Table 3.2-1, HB ISFSI Emergency Action Levels, states (in part):
Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than 0.30 mrem/hr* on the lid of the ISFSI Vault. (NOTE:
Contact reading not needed if any reading greater than 0.30 mrem/hr near the vaults is found.)
However, EP requirements, as exempted to date, still provides for the following:
- 10 CFR 50.47 (b)(9), as exempted (9) Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.
- 10 CFR 72.32(a), provides, (4) Detection of accidents. Identification of the means of detecting an accident condition.
- 1. Is the Emergency Coordinator qualified to operate radiation monitoring equipment to determine the specific ISFSI radiation levels to declare the Alert? If so, is the equipment readily available? If not, what is the timeliness of the assessment and classification?
- 2. What conditions would initiate performance of these surveys? Is this required by procedures?
RAI-HB-04
- Enclosure 3, Table 3.2-1, HB ISFSI Emergency Action Levels, states (in part):
- SECURITY CONDITIONS that would require declaration of an Alert are defined within the Emergency Plan implementing procedures.
What procedure has this information and who performs this procedure? How is this procedure controlled?
RAI-HB-05
- Enclosure 4, Page 13 of 39, Table 3.2-1, states (in part):
Accident scenarios were reassessed based on the status of decommissioning. Source terms have diminished to a point that declaration of a NUE or Alert based on radiological conditions is unlikely. Administrative controls were included in the HBPP DSAR, Appendix A, to limit the source term and implement event precursor controls to control potential radiological effluents below the thresholds associated with a NOUE or Alert.
What justification/guidance was considered to eliminate EALs based on the use of administrative controls? If administrative controls fail, would there be a release of sufficient quantity to declare the effluent EALs?
RAI-HB-06
- Enclosure 3, Section 4.1, Site Emergency Response Organization, states (in part):
The Emergency Coordinator is qualified and responsible for making an initial evaluation of the incident, performing any immediate actions which are necessary, making required notifications, and placing appropriate portions of the Emergency Plan into effect.
Does the Emergency Coordinator training program provide for familiarization with the ISFSI designs, operations and radiological concerns?
RAI-HB-07
- Enclosure 3, Section 4.1, Site Emergency Response Organization, states (in part):
Management staff will be available by phone for advice and guidance for the on-site Emergency Coordinator, if needed.
Please provide further justification why a responder with technical and/or radiological expertise is not a designated, augmented position based on the criteria for declaring an Alert. When the entry criterion for the Alert is met, there are indications of possible confinement damage.
RAI-HB-08
- Enclosure 3, Section 5.1.2, Notification of Public Authorities, states (in part):
Information to be communicated to offsite response organizations includes, as applicable: the status of the site and ISFSI including important structures, systems, and components; information regarding potential impacts for offsite personnel; and required responses from the offsite responders. Provisions are included for message authentication.
- Enclosure 4, Page 26 of 39, states (in part):
Radiological releases were eliminated in this discussion since no EALs are based on radiological release from an ISFSI.
However, 10 CFR 72.32(a), still provides for the following:
(9) Information to be communicated. A brief description of the types of information on facility status; radioactive releases; and recommended protective actions, if necessary, to be given to offsite response organizations and to the NRC.
How is information related to potential radioactive releases provided?
RAI-HB-09
- Enclosure 3, Section 5.2, General Assessment and Protective Actions, states (in part):
Event assessment via direct observation and use of installed or portable instrumentation.
- Enclosure 4, Page 29 of 39, states (in part):
There is no longer a source term for liquid or airborne releases. Under the revised organization, the Emergency Coordinator solicits assistance as required to perform support functions as assigned based on event.
However, 10 CFR 72.32(a), still provides for the following:
(6) Assessment of releases. A brief description of the methods and equipment to assess releases of radioactive materials.
How are potential radioactive releases assessed? Who performs this assessment and what is the timeliness of the assessment?
RAI-HB-10
- Enclosure 4, Page 33 of 39, states (in part):
At the time of E-Plan approval, some RP related facilities and equipment may remain onsite to support the decommissioning and be available. However, there are no radiological based EALs, so the discussion is limited to the equipment available long term.
However, 10 CFR 72.32(a), still provides for the following:
(4) Detection of accidents. Identification of the means of detecting an accident condition.
Since the ISFSI EAL is based on a dose rate reading, how is it assessed and will there be equipment maintained to perform that assessment?
RAI-HB-11
- Enclosure 3, Section 8.3.2, Exercises, states (in part):
PG&E conducts a biennial emergency exercise for a simulated emergency that includes radiological, medical and fire aspects.
- Enclosure 4, Page 37 of 39, states (in part):
Although a reduction in the frequency of emergency exercises, the biennial frequency is consistent with regulatory guidance and a facility with a limited source term.
However, 10 CFR 72.32(a), still provides for the following:
(12) Exercises. (i) Provisions for conducting semiannual communications checks with offsite response organizations and biennial onsite exercises to test response to simulated emergencies. Radiological/Health Physics, Medical, and Fire drills shall be conducted annually.
Will Radiological/Health Physics, Medical, and Fire drills be conducted annually?