ML20210C531
| ML20210C531 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 04/30/1987 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20210C515 | List: |
| References | |
| NUDOCS 8705060220 | |
| Download: ML20210C531 (92) | |
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m SAFETY EVALUATION REPORT HUMBOLDT BAY POWER PLANT UNIT NO. 3 DECOMISSIONING DOCKET NO. 50-133 PACIFIC GAS AND ELECTRIC COMPANY 9
APRIL 1987 D
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a TABLE OF CONTENTS P_ age, a
1 INTRODUCTION.................................................
1-1 1.1 Background..............................................
1-1 1.2 Proposed Action.........................................
1-2 1.3 Decommissioning Alternatives............................
1-2 1.3.1 DECON............................................
1-2 1.3.2 ENTOMB...........................................
1-2 1.3.3 SAFSTOR..........................................
1-3 2 DESCRIPTION OF PLANT.........................................
2-1 2.1 Humboldt Bay Power Plant Unit 3.........................
2-1 2.2 Spent Fuel Pool.........................................
2-1 2.2.1 Modifications to Spent Fuel Pool.................
2-7 2.2.2 Material in Fuel Assembly Can....................
2-7 2.2.3 S a f e ty Fe a tu re s..................................
2-7 2.2.4 Pool Leakage.....................................
.2-11 3 SITE GEOLOGY, SEISMOLOGY, AND HYDROLOGY......................
3-1 3.1 Summary Geologic and Seismic Site Status................
3-1 3.2 Hydrologic Description..................................
3-2 3.2.1 Flood Potential..................................
3-2 3.2.2 Runoff Flooding..................................
3-3 3.2.3 Wind and Wave Action.............................
3-3 3.2.4 Tsunami Flooding.................................
3-3 3.2.5 Local Intense Precipitation......................
3-4 3.2.6 Summary of Staf f Hydrologic Position.............
3-4 4 PROPOSED DECOMMISSIONING PLAN................................
4-1 4.1 Preparations for SAFSTOR...........................,....
4-1 4.2 Activities During SAFSTOR Period........................
4-2 5 TECHNICAL SPECIFICATIONS.....................................
5-1 6 ADMINISTRATIVE CONTROLS 6-1 6.1 Organization and Responsibilities.......................
6-1 6.1.1 Corporate Organization...........................
6-1 6.1.2 Operating Organization...........................
6-4 6.1.2.1 ProjectManager.........................
6-4 6.1.2.2 Plant Manager...........................
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6.1. 2. 3 Plant Staff Qualifications..............
6-4 6.1.2.4 Operating Shift.........................
6-8 6.2 Training................................................
6-9 6.2.1 General Employee Training........................
6-9 6.2.1.1 Description of Plant and Facilities.....
6-9 6.2.1.2 General Site Rules......................
6-10 6.2.1.3 Radiation Protection Program............
6-10 6.2.1.4 Respiratory. Protection..................
6-10 6.2.1.5 Site Emergency Plans....................
6-10 6.2.1.6 Industrial Safety, First Aid, and Fire Protection..............................
6-11 6.2.1.7 Security Program........................
6-11 6.2.2 Technical Trianing...............................
6-11 6.2.2.1 Radiation Protection Department Training Program.................................
6-11 6.2.2.2 Use of Monitoring Equipment.............
6-12 6.2.2.3 Certified Fuel Handlers.................
6-13 6.2.2.3.1 Training and Certification Requirements for Fuel Handlers.....................
6-13 6.2.2.3.2 Training Program for Certified Fuel Handlers......
6-13 6.2.2.3.3 Certified Fuel Handler Requalification Training Program......................
6-14 6.2.2.4 Quality Assurance / Control Program.......
6-15 6.2.3 Other Decommissioning Training...................
6-15,
6.2.3.1 Radioactive Waste Volume Minimization...
6-15 6.2.3.2 Decontamination Workers.................
6-15 6.2.4 Training Program Administration and Records......
6-16 6.3 Quality Assurance.......................................
6-16 6.3.1 Organization.....................................
6-16 6.3.2 Quality Assurance Program........................
6-16 6.3.3 Quality Assurance Conclusions....................
6-17 7 OCCUPATIONAL HEALTH AND SAFETY...............................
7-1 7.1 Health Physics and Safety Management....................
7-1 7.2 Radiation Sources.......................................
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7.3 Dose Commitment.........................................
7-2 7.4 Health Physics Program..................................
7-2 7.5 Health Physics Instruments, Equipment and Facilities....
7-2 7.6 Health Physics Procedures...............................
7-2 8 F I NANC I A L P LAN...............................................
8-1 9 RADI0 ACTIVE WASTE MANAGEMENT.................................
9-1 9.1 Liquid and Gaseous Waste Management Systems.............
9-1 9.1.1 Systems Description and Review...................
9-1 9.1.2 Acceptance Criteria..............................
9-2 9.1. 3 Evaluation Findings..............................
9-2 9.2 Solid Waste Management Systems..........................
9-2 9.2.1 Systems Description and Review...................
9-2 9.2.2 Acceptance Criteria..............................
9-4 9.2.3 Evaluation Findings.............................. 4 9.3 Process and Effluent Radiological Monitoring and Sampling Systems................g................................
9-4 9.3.1 System Description and Review....................
9-4 9.3.2 Acceptance Criteria..............................
9-5 9.3.3 Evaluation Findings..............................
9-5 10 POSTULATED ACCIDENTS.........................................
10-1 10.1 Fuel Handling Accident..................................
10-1 10.2 Non-mechanistic Heavy Load Drop / Site Related Hazards....
10-2 10.3 Criticality Potential of Rearranged Stored Spent Fuel Due to Seismic or Other Mechanical Loads................
10-2 10.4 Non-mechanistic Expulsion of Pool Water and Radionuclide Contaminants to the Atmosphere..........................
10-3 10.5 Spent Fuel Pool Rupture
............a....................
10-3 10.6 Uncontrolled Release of Radwaste Tank Contents..........
10-4 10.7 Impact of Tsunami Flooding..............................
10-5 10.8 Accident Analyses Conclusions...........................
10-5 11 EMERGENCY PLANNING...........................................
11-1 11.1 Introduction............................................
11-1 11.2 Evaluation of the Emergency Plan........................
11-2 11.2.1 Emergency Classification System................
11-2 11.2.2 Emergency Facilities and Equipment.............
11-2 11.2.3 Emergency Communications.......................
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s TA8LE OF CONTENTS (continued) g-4 11.2.4 Medical and Public Health Support..............
11-4 11.2.5 Assignment of Responsibility (Organization 1
Contro1)........................................
11-4 11.2.6 Onsite Emergency Organization..................
11-5 11.2.7 Emergency Response Support and Resources........
11-5 11.2.8 Noti fication Nethods and Procedures............
11-6 11.2.9 Public Education and Information...............
11-6 11.2.10 Accident Assessment............................
11-6 11.2.11 Protective Response.............................
11-7 11.2.12-Radiological Exposure Control..................
11-8 i
11.2.13 Recovery and Reentry Plannin 11-8 Exercises and Drills.......g 11.2.14 11-8 11.2.15 Emergency Response Training....................
11-9 11.2.16 Responsibility for the Planning Effort:
Development, Periodic Review and Distribution of Emergency Plans................................
11-9 11.3 Emergency Planning Summary...............................
11-9 i
12 CONCLUSIONS..................................................
12-1 13 CONTRIBUTORS.................................................
13-1 14 REFERENCES...................................................
14-1 i
APPENDIX A PUBLIC UTILITIES CONNISSION, STATE OF CALIFORNIA, HUNBOLDT BAY UNIT 3 DECOmtISSIONING FUNDING DECISION N0. 85-12-022 i
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1 INTRODUCTION 1.11 8ackaround Humboldt Bay Power Plant Unit 3 (Humboldt Bay Unit 3) received a construction i-permit on October 17, 1960.
Provisional Operating License DPR-7 was issued in August 1962 and commercial operation began in August 1963.
On May 17, 1976,.
the NRC issued an order which required the satisfactory' completion of a speci-fled. seismic design upgrading program and resolution of specified geologic and seismic concerns prior to power operation following the'1976 refueling outage.
On July 2,1976, Unit 3 was shut down for refueling and seismic modifications.
In 1983, the ifcensee (Pacific Gas and Electric Company) concluded that the seismic and TMI modifications
- required for restart were uneconomical and decided to decommission the plant.
By letter dated July 30, 1984 (Schuyler, 1984), the l'icensee proposed (1) to amend License DPR-7 to possess-but-not-operate status; (2) to delete certain -
Ifcense conditions related to seismic modifications required before the NRC would authorize a return to power operation; (3) to revise the Technical Speci-
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fications (TS) to reflect the possess-but-not-operate status; (4) to decommis-sion Humboldt Bay Unit 3 in accordance with the plan included with the submittal; and (5) to extend License No. DPR-7 for 15 additional years, to November 9, 2015, l
to be consistent with the decommissioning plan.
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In response, the staff issoed License Amendment 19 on July 16, 1985 (NRC, 1985) 1 revising License DPR-7 to possess-but-not-operate status (Item 1 above).
Also, in accordance with the provisions of the National Environmental Policy Act (NEPA) of 1969, a Draft Environmental Statement (DES) (NUREG-1166,'
April 1986) was issued by the NRC. The DES sets forth the environmental con-siderations related to the proposed decommissioning of Humboldt Bay, Unit 3.
The Final Environmental Statement (FES) (NUREG 1166) provides responses to public comments received on the DES and appropriate revisions to the DES.
Before granting approval for the decommissioning of a nuclear power plant or an amendment to a license, the NRC is required to conduct.a review'of the effects of the proposed ~ action on the public health and safety and the safety _
j of plant workers. This Safety Evaluation Report (SER) summarizes the results j
of the staff's review of the proposed amendment to License No. DPR-7'to accom-plish items 2 through 5 above. The amendment would delete seismic requirements related to reactor operation, revise the TS as~ proposed, approve the proposed decommissioning plan and extend License No. DPR-7 for 15 additional years as proposed in the plan.
- Modifications necessary to comply with requirements imposed after the accident at Three Mile Island (TMI) Unit 2.
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- 1. 2 Proposed Action The proposed action would permit safe storage of Humboldt Bay Unit 3 and delayed dismantling of the unit after the 30 year storage period..This action is needed to provide for safe control of the residual radioactivity to ensure the protec-tion of the health and safety of the public and the environment until-the radio-activity is removed from the site.
The spent fuel pool will store 390 spent fuel assemblies and 54 in-core fission chambers until the Department of Energy (DOE) has a permanent Federal repository for spent fuel.
The licensee has provided a preliminary dismantling plan (Schuyler, 1984) that will be the basis for the final dismantling plan.
The final plan, which will support the application for termination of the unit's license, will be provided near the end of the 30 year storage period for NRC Staff approval.
1.3 Decommissionino Alternatives The purpose of decommissioning a nuclear facility is to take the facility safely from service and to remove the associated radioactivity from the property so that the facility can be released for unrestricted use. A licensee can propose to decommission a nuclear power plant using one of three methods: DECON, ENTOMB, or SAFSTOR.
Each of these is addressed below.
1.3.1 DECON In the DECON method, equipment, structures, and those portions of the facility containing radioactive contaminants are removed or decontaminated to a level that permits the property to be released for unrestricted use shortly after operations stop. This alternative is not presently feasible for Humboldt Bay Unit 3 because the spent fuel assemblies must be stored on the site until a permanent Federal repository is ready to receive them.
(A Federal repository is not likely to be ready to receive spent fuel until after 2003.)
1.3.2 ENTOMB The ENTOMB alternative involves encasing radioactive contaminants in a struc-turally long-lived material, such as concrete.
The entombed structure is appro-priately maintained, and there is continued urveillance until the radioactivity is removed from the site or decays to a level that permits unrestricted use of the property.
Long-lived radionuclides such as niobium-94 are likely to be present in the reactor vessel so that waiting for decay would be impractical.
For entombment, there may be no need for a full-time onsite security guard force, and less radiation monitoring and environmental surveillance would be required because all radioactive material is contained within the entombment barrier.
However, in this case, because the spent fuel will remain on the site until a Federal repository is ready to accept the spent fuel, a full-time security force and adequate radiation monitoring and environmental surveillance would be required. Thus the need for these spent fuel storage safety provisions and the presence of long-lived radionuclides makes it impractical to entomb Humboldt Bay Unit 3.
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1.3.3 SAFSTOR The SAFSTOR alternative involves placing a nuclear facility in a safe condi-tion and maintaining it in that state until it is dismantled and all remaining radioactive materials that would restrict use are removed.
The facility may be left intact, except that all fuel assemblies should be removed from the reactor and radioactive fluids and wastes should be removed from the site.
1 The licensee selected the SAFSTOR alternative because:
(1) It is the most cost-effective of alternatives available while there is no Federal repository for spent fuel.
(2) It allows radionuclide decay over time, so that when final dismantling takes place, occupational radiation exposures are reduced.
This alternative includes the storage of spent fuel assemblies in the spent fuel storage pool.
Storing spent fuel assemblies at Humboldt Bay Unit 3 until a repository is available results in less radiation exposure to workers and to the public than temporary storage at another location, when handling and trans-shipment operations are considered.
In the accident analysis (Sections 10.4 and 10.5), no credit is given for the seismic integrity of the facility, and conservative assumptions are made with respect to seismically-triggered' hypothetical events.
Other alternatives for disposition of the spent fuel are evaluated in the FES (NUREG 1166) but were found to be not available at this time and to have no significant environmental advantage.
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The plant was operated commercially for the production of electrical energy from August 1963 to July 1976 under License DPR-7.
The Humboldt Bay Power Plant (HBPP) site plan is shown in Figure 2.1.
Humboldt Bay Unit 3 is located alongside two fossil-fueled power plants (Humboldt Bay Units 1 and 2). Two gas turbine units are designated mobile emergency power plants.
The plant structures and equipment are shown in Figures 2.2 and 2.3.
The reactor primary containment, located below grade, consists of the drywell vessel, which contains the reactor, and the suppression chamber.
The drywell and suppression chamber are located inside a concrete caisson. The refueling building encloses the space above the caisson.
The refueling building contains the spent fuel storage pool and the new fuel storage vault in addition to the reactor caisson.
Next to the refueling building are the power building and turbine pedestal. The power building contains the condenser, feedwater and condensate systems, steam cycle auxiliary systems, and the control room. The turbine generator is located on the turbine pedestal.
Liquid and solid wastes are processed in the radwaste treatment facilities.
2.2 Spent Fuel Pool The spent fuel pool contains storage racks having a total capacity of 486 fuel assemblies (Figure 2.4).
There are 351 central pool locations in 87 groups of four and 1 group of three.
Also, there are 135 peripheral pool locations in 45 groups of three.
The central racks are designed to individually support each fuel assembly. The peripheral racks support fuel assemblies in groups of three.
The central storage racks (Figure 2.5) are constructed of aluminum and consist of pairs of storage units approximately 5 feet high and 12 inches square.
Each storage unit is able to hold four fuel assemblies.
The peripheral racks are similarly constructed except that they can hold only three fuel assemblies.
The fuel storage racks are welded and/or bolted to cross members of aluminum channels.
The fuel storage racks are spaced to be " criticality safe." Further, since the reactor has not operated for more than 10 years, the decay heat now generated in the spent fuel by the fission producct inventory has decreased to a level that no longer requires cooling systems to prevent fuel melting.
The spent fuel, which generates no more than 100 watts per assembly, can be ade-quately cooled without water by natural convection of air (Shifter, February 28, 1985, Appendix B).
Humboldt Bay Unit 3 was placed in cold shutdown in July 1976.
The fuel was removed from the reactor early in 1984.
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pool contains 390 spent' fuel assemblies and 54 in-core' fission chambers. These units will remain in storage unti1~the DOE has'a repository ready'to receive.
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them. The fuel fission product inventory is approximately 1 x 10 curies.
A cover (a contamination control barrier) will be installed over the spent fuel' pool to mitigate'the spread of small amounts of contamination that may be re-leased from the pool and to provide protection against objects dropping into the pool. The pool contamination control barrier will be tied into a radiation-
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The inventory of activation products in the plant is about 1 x 104 curies.
Approximately 67 curies on contaminated surfaces are also within the plant inventory.
2.2.1 Modifications to Spent Fuel Pool In order to preclude criticality in the spent fuel storage pool following an event which results in movement or damage to the fuel assembly storage racks, each fuel assembly has been enclosed in a can fabricated from a neutron-absorbing material.
The can contains an areal density (0.005 ge/cin ) of 2
boron (B-10) to maintain K,ff less than 0.95 (Shiffer. July 1985).
Drawings of the can are shown in Figures 2.6, 2.7, and 2.8.
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tm can have been fabricated from Boral Three bands are attached at the top, middle, and bottom of the can to provide structural strength. Additional sup-ports are provided by corner angles, as necessary, as shown in Figures 2.6 and 2.7.
A band has been attached to the bottom of the can to prevent the fuel assembly from coming out of the bottom. The top band has been fabricated with locking tabs which will be bent over to prevent inadvertent removal of the fuel assembly from the can. This design is to ensure that the poisoned material is an integral part of the fuel assembly.
2.2.2 Material in Fuel Assembly Can Most of the material used in fabrication of the fuel assembly enclosure can is Boral, which is a thermal neutron poison material composed of boron carbide and 1100-alloy aluminum. Boron carbide is a compound having a high boron content in a physically stable and chemically inert form. The 1100 alloy aluminum is pro-
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The Boral is provided in flat sheets and is formed to enclose the full length l
of each of the four sides of each individual fuel assembly.
Physical integrity i
of the poisoned can is maintained by use of type 304 stainless steel bands which are attached to the Boral with aluminum rivets and encircle the can at the bottom, the approximate center, and the top.
l The materials contained in the Boral, as well as the stainless steel, are chemically compatible with all parts of the spent fuel storage system, including the fuel assemblies, the cooling system, the cleanup system, the pool liner, and the storage racks.
2.2.3 Safety Features To ensure safe storage of spent fuel and to minimize release of activity, the licensee has taken the following additional steps:
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1.
~ a redundant level indicating system is provided to alarm low water level in the Spent Fuel Storage Pool (TS V.B.5).
. 2.
Water Chemistry is maintained to minimize corrosion (TS III.B.2.b.,
Table III-2).
3.
Radioactivity levels in the pool water are monitored to provide an indica-tion of fuel integrity (TS III.B.2.b, Table III-2). An ion exchange system maintains radioactivity level or less than 1 x 10 4 pCi/ml.
(TS,
-Table III-2).
4.
Spent fuel is stored in a configuration to provide maximum separation of assemblies during the SAFSTOR period (TS III.A.2).
5.
Spent fuel handling operations have detailed written procedures that are reviewed by the Plant Staff Review Committee and approved by the Plant Manager (TS VII.E.2.).
Spent fuel handling operations are under the direct supervision of a Certified Fuel Handler.
(TS VII-C.1.d) 6.
Spent Fuel Storage Pool makeup water is provided from the demineralized water system which is supplied by the condensate storage tanks.
Emergency makeup is from the plant fire system (TS III.A.2).
7.
Maintenance is performed on structures, systems, and components as re-quired to ensure safe storage of the spent fuel (TS VII.D.2).
The staff concludes that the above actions are adequate to provide for the safe storage of the spent fuel.
2.2.4 Pool Leakage The Spent Fuel Storage Pool developed a leak in March 1966.
A stainless steel liner covering the inside surface of the pool was installed which formed a 1/4-inch gap between the walls and floor of the pool and liner. The water level is maintained in this gap at a level below the pool level and below the exterior groundwater level using a liner gap pump to minimize the potential for leakage from the Spent Fuel Storage Pool to the ground water surrounding the pool (TS III.B.2.a). The water from the liner gap is pumped to the radwaste system.
The pump is operated for 10 to 15 minutes, approximately once per week, to maintain the water level below the TS limit.
A test in January 1985 measured the liner leak rate.
Liquid samples were taken from the spent fuel pool and liner gap to determine tritium activity.
The spent fuel storage pool tritium activity was 686 pCi/ml, while that of the gap was 30.5 pCi/ml.~
(Groundwater leakage diluted the spent fuel storage pool leakage into the gap.) The gap tritium level indicated that the spent fuel storage pool leak rate into the liner gap is about 0.45 1 (0.12 gallon) per day and the corresponding groundwater leak rate is about 9.67 1 (2.5 gallons) per day.
On December 23, 1986, the spent fuel pool gap water level monitoring system was found to be defective during the installation of a new redundant level monitoring system (Shiffer, January 1987). The gap water level was also found to be higher than the administrative limits.
PG&E found no indication of radiation levels Humboldt Bay 3 SER 2-11
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above background in any of the monitoring wells, however. 'Also, the radio-activity in the water in the french drain below the pool indicated no signifi-cant change in concentration of radionuclides.
PG&E has now completed the installation of a redundant gap water level monitor-ing system which will eliminate the single-failure problem discussed above.
In addition, a new high-capacity, ion-exchange system is now installed for the spent fuel pool. -The proposed TS limits require that the pool water be main-tained at cesium-137 concentrations of no more than 1 x 10 4 pCi/ml.
For com-parison, 2 x 10 5 pCi/ml is the cesium-137 concentration limit of.10 CFR Part 20 Appendix B, Table II for water released to unrestricted areas.
The staff has determined that there will not lik31y be a significant amount of radioactivity transferred from the spent fuel pool to the groundwater because:
(1) the pool water radianuclide concentrations are maintained at levels close to that acceptable for release to unrestricted access, (2) the gap water is maintained at a level that is less than pool level and groundwater level, and (3) if the liner gap pump failed, there would be sufficient time to repair or replace it before the gap water level increased above groundwater level since the gap water level increases only about 3 inches per day (Shiffer, October 1986).
Since the spent fuel water is maintained at low levels of radioactivity by ion exchange cleanup, the pool leakage to the gap is very low, and the gap water level is maintained below the pool and groundwater level, we have reasonable assurance that the pool' leakage will have no environmental significance and will not affect the health and safety of the public.
On February 17, 1987, the NRC staff collected samples of groundwater from the sampling wells to complete an independent analysis of radionuclide concentra-tions. The analysis of these samples is scheduled for completion in May 1987.
6 Humboldt Bay 3 SER 2-12 l
3 SITE GE0 LOGY, SEISMOLOGY, AND HYDROLOGY-A summary of the geologic and seismic status of the Humboldt Bay site is pro-vided. The staff did not complete its review of the geologic / seismic site issues when the licensee withdrew its application for an amendment that would permit the restart of the facility under the terms of the Commission's May 1976 order. The staff's accident evaluation, therefore, gives no credit for the seismic integrity of the facility; i.e.,
the staff assumes that plant struc-tures would be breached as a -esult of a seismic event..Also, the calculations are deliberately conservative with respect to seismically-triggered hypotheti-cal events.
A summary of site hydrologic considerations is given. Staff accident evaluation assumptions with respect to radionuclides entering the tidal affected water table aquifer and Humboldt Bay through flow down gradient are also deliberately conservative (Section 10).
3.1 Summary of Geologic and Seismic Site Status In conjunction with issuance of the full power operating license for Humboldt Bay Unit 3, in 1969, PG&E was requested to perform an updated seismic study of a
the site. The license was then modified in 1976 because of several still unresolved geologic and saismic concerns. The modification required the 11-censee to resolve the outstanding issues before restart would be permitted.
Several submittals by the licensee had not provided sufficient evidence to demonstrate that surface faulting will not occur at the site, or to substantiate the adequacy of the seismic design.
At issue was the fact that Humboldt Bay Unit 3 is located in close proximity to several mapped faults, the nature, extent, and age of which were not well established and in an area of " transitional" tectonics where the stresses, type of deformation, and seismic sources were not well defined.
In order to address the license modification and qualify for restart, the licensee engaged a geological consultant who began a 2 year investigative pro-gram in 1978 to determine if there was. sufficient information available in the area to resolve the outstanding issues. The report (Woodward-Clyde Consultants, October 1, 1980), addressed the geometry, extent, amount of offset, age and slip rate of the two most significant faults, the Bay Entrance and Little Salmon Faults, near the site. The consultants concluded as the result of trenching and drilling information that the two faults are capable within the meaning of Ap-pendix A to 10 CFR Part 100 but with very low probability of surface displace-ment. Additionally,they examined the microearthquake record and suggested that there is sufficient information to determine a strike-slip mechanism for most microearthquakes in the area, and to evaluate the ground motion potential and soil-structure interaction.
The region in which Humboldt Bay Unit 3 is located is one of relatively high seismicity when compared to other regions of California. The site is approxi-mately 50 kilometers north of the Mendocino Fracture Zone and about Humboldt Bay 3 SER 3-1
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250 kilometers east of the Gorda Ridge, a seismically active spreading center, and the Blanco Fracture Zone, a seismically active transform fault.
Since the licensing of the Humboldt Bay Unit 3, there have been at least twelve earthquakes of magnitude 5 or greater and numerous smaller events within 100
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kilometers of the site. Many of these events have been reported _to have caused damage in the region.
The most significant of these earthquakes was the November 8,1980 Magnitude 7 event which had its epicenter over 60 kilometers from the site. Following this earthquake, a team of NRC staff engineers and a geologist visited the site to examine the effects of the earthquake on the plant, the site, and the region.
.A report on the effects of the earthquake on the plant structures was published in April 1981 as NUREG-0766. Conclusions of this report were that the peak ground acceleration in the free-field at the plant may have been in the range of about 0.15g to 0.25g in the east-west direction. The report also concluded that the effects of the earthquake on Humboldt Bay Unit 3 were minimal and did not endanger the health and safety of the public.
The staff did not complete its review of the licensee's 1980 report, but ter-minated that review when the licensee withdrew its application for restart.
Since the geologic and seismic analyses were not completed, the staff's accident analysis (Section 10) gives no credit for the seismic integrity of the facility structures or components.
License conditions related to seismic modifications and geologic studies and investigations required before the NRC would authorize a return to power operation (NRC Orders, May 1976 and December 1976) may be deleted, as these conditions do not require any action by the licensee with the plant permanently shut down.
3.2 Hydrologic Description The Humboldt Bay Power Plant is located on the mainland shore of Humboldt Bay just opposite the Bay entrance from the Pacific Ocean in northern California.
Humboldt Bay is about 14 miles long and varies in width from 0.5 mile to 4 miles. At the plant site the Bay is about 1.5 miles wide. The area of the Bay at Mean Lower Low Water (MLLW) is about 11 square miles.
Four major streams drain into Humboldt Bay - Salmon Creek, Elk River, Fresh-water Creek and Jacoby Creek. These four streams have a combined drainage area of about 158 square miles.
The plant grade is at elevation +12 feet above MLBi and the seaward side of the hill upon which the plant is located is protected from wave action by a revet-ment. The revetment is located about 400 feet to the north of the reactor building, facing Humboldt Bay. The revetment extends up to +16 feet above MLLW. The licensee stated that the plant is protected against the static'and dynamic effects of a tsunami up to an elevation of +20 ft above MLLW (Shiffer, April 1985).
3.2.1 Flood Potential l
Three sources of general area flooding were investigated by the licensee. One was the combination of runoff flooding in Humboldt Bay with high tides, another i
l was wind induced surge and wave action, and the other was a distantly generated Humboldt Bay 3 SER 3-2
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' tsunami. The l'icensee also investigated.the effects of local intense.
zprecipitationion the plant site drainage 1 system. The-staff agrees.that these' are-the logical sources of-flooding to be-investigated for-the plant site.
1 3.2.2 ; Runoff Flooding j
f
.The, licensee evaluated the. upper limit.of. flood potential from runoff into Humboldt Bay by estimating the probable maximum flood (PMF) resulting from'the probable maximum precipitation (PMP) (Shiffer, July 1985). The licensee divided the drainage area above-the four creeks and the Bay into-15 sub-basins, each with. unit hydrographs and associated routing reaches. The 72-hour winter PMP was-determined for each sub-basin-using'Hydrometeorological Report No. 36
.(U.S. Weather Bureau, October 1969). A flood hydrograph was then. computed by the licensee and the resulting rise in water level in the. Bay was_ estimated to
.be about 0.10 feet above tide-level.
1 Historical astronomical tides' were also investigated by-the: licensee. 'Using
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data from the National Ocean Survey, the_ licensee listed the annual highest i
tide levels recorded in Humboldt Bay between the-years 1920 and.1983. Although an elevation ~of +12.5 feet MLLW was recorded in-November:1981 atithe North. Spit location, this could not be verified and may be an erroneous reading. _ An eleva-tion of +9.5 feet MLLW for the South Jetty gage (Harris, February-1981) probably best represents the highest expected astronomical tide'at the site.
i Based upon these-assessments, the staff concludes that-the PMF, even when com-
~
bined with an extreme high tide, will not exceed-the plant grade elevation off j
+ 12 feet MLLW.
3.2.3 Wind and Wave Action
)
The-licensee performed an analysis of wind wave generation and setup as part-of PMF analysis. Winds that could be considered likely to occur.at the site during the PMP storm were used to calculate wave runup and~ arrive at a maximum water level. The licensee also calculated wind wave generation from.a 100 year-recurrent wind (62 mph) and a 100 mph wind. The various winds were applied on the Mean Higher High Water (MHHW) level aof +6.7 feet-MLLW.-. Although the licensee i
did not investigate the combination of extreme astronomical-tides and extreme.
winds, it was apparent from the calculations presented'that the revetment 1
(elevation +16 feet MLLW) is not likely to be-overtopped by wave action from extreme combinations of wind and tide.
The staff concludes that the revetment is capable of protecting the plant from wave effects and erosion from storms having.a recurrence. interval of more than-100 years.
1
'3.2.4 Tsunami Flooding
- ~
The licensee investigated the site's potential for tsunami flooding using three, separate _ sources of information. The _ first source.was the probabilistic study of historical tsunamt performed by R. L. Wiegel -for the_ original' plant' safety _
study. According to Wiegel, a tsunami with a runup to elevation +20 feet MLLW.
has an interval of probable occurrence of.once in 5000' years (Shiffer,; April.
3' 1985). The licensee-has' stated that Unit 3 is adequately protected against the t
dynamic and static forces of such a tsunami.-
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The licensee also attempted to calculate probable maximumLtsunami runup'using-
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" Tsunami Atlas ~for the Coasts of the United States"-(NUREG/CR-1106). :From this-publication, the licensee obtained an estimate ofLthe wave shape off the con-tinental shelf, and the, licensee then determined the shore line water level due to shoaling (there was no refraction). The. licensee did not determine the increase in water depth due to runup, however. The licensee's estimate.for probable maximum tsunami level was +16.1 feet MLLW, which the staff does.not consider to be conservative.
l The third source of information considered was from a study prepared by the Corps of Engineers for.the Federal Insurance Administration, FIA, (Houston, 1978).
In this publication a procedure similar to.that used in the " Tsunami-Atlas" was used to generate far field (distant' source). tsunami.
In the.FIA, study, runup was also added to the estimate to delineate-the amount of-expec-ted flooding along the Pacific Coast. For the plant site'a 500 year-recur-rent tsunami runup elevation of +20.7 'feetLMLLW was determined from the study.
It.should be noted that the FIA 500 year estimate is slightly greater than -
l Wiegel's 5,000 year estimate.. The staff' considers the FIA study to be conser-vative and the authors of the FIA study suggest that the 500 year value may.
[._
. represent the upper limit of tsunami potential at the site. Based on the re-sults of the FIA studyLand Wiegel's study, the staff. considers the present level of protection of 20 feet MLLW to be adequate:for at least the 500 year tsunami. The staff considers potential accidents caused by tsunami flooding ~in Section 10.7.
3.2.5 Local Intense Precipitation i
The effects of local intense precipitation on the plant site drainage system were investigated by the licensee using point values of the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> PMP..The.
licensee determined that the volume of the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> PMP could cause flooding up to elevation +9 feet MLLW. A short' duration thunderstorm PMP was also investi-gated as a potential source of plant site flooding.
The licensee's analysis shows the plant to be safe from local intense precipi-3 tation. The staff concurs and concludes that local intense precipitation does not pose a threat to the spent fuel facility.
3.2.6 Summary of Staff Hydrologic Position It is the staff's position that the licensee's submittal-does not provide all of the data and analysis that would normally be required to show that an operat-ing reactor sites meets General Design Criterton 2 (10 CFR 50, App. A).
In particular the analysis and information provided fail to meet the criteria-of SRP 2.4.5 " Probable Maximum Surge and Seiche-Flooding" and SRP 2.4.6 " Probable r
Maximum Tsunami Flooding." However, the staff is' satisfied that the-licensee's i
plant design basis provides protection from a tsunami with a recurrence interval of at least 500 years. The staff estimates a recurrence. interval of at least.
100 years for a wind induced surge and accompanying wave' action.that could damage the revetment. Only a repeated occurrence of such a storm, or a worse L
one before the revetment could be repaired, could cause serious erosion at the plant site. -It should also be recognized that the Humboldt Bay site is no a
7 longer an operating reactor site that requires a high degree of flood protec-tion,.but a site proposed for the storage of spent fuel that has decayed for
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more than 10 years. For a discussion of the impact.of tsunami flooding, the one flooding event that could inundate the site, see the staff's accident.
evaluation, Section 10.7.
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I 4 PROPOSED DECOMMISSIONING PLAN The Humboldt Bay Unit 3 decommissioning plan proposed by the licensee is SAFSTOR for a period of 30 years followed by DECON.
SAFSTOR requires that a nuclear facility be placed and maintained in such a condition that it can be safely stored and subsequently decontaminated (deferred DECON). DECON requires that equipment, structures, and portions of a facility and site containing radio-active contaminants be removed or decontaminated to a level that permits the property to be released for unrestricted use.
4.1 Preparations for SAFSTOR In preparation for SAFSTOR, the licensee has completed or is completing tasks that are permitted under the operating license (DPR-7).and the July 16, 1985 possess-but-not-operate amendment. These activities include:
(1) removing-irradiated fuel assemb1'ies and in-core fission chambers and trans-ferring them to the spent fuel storage pool where they will remain until DOE has a permanent Federal repository to receive them*
(2) draining the reactor vessel and reactor cooling system
- i (3) processing, packaging, and shipping radioactive waste to a low level waste disposal facility (4) removing certain pipe sections and components that are significant contrib-utors to dose rates in work areas (to implement the ALARA program)
(5) decontaminating selected components Approval of the decommissioning plan and the extension of the possess-but-not-operate license will allow decommissioning of Humboldt Bay Unit 3 in the SAFSTOR mode for a period of 30 years.
When approval of SAFSTOR is granted, the licensee will perform the following activities:
(1) complete the layup of systems not required during SAFSTOR (2) complete the modifications of the spent fuel storage pool facilities (3) complete planned decontamination of systems and components (4) process, package, and ship offsite radioactive waste generated by SAFSTOR activities (5) perform baseline radiological surveys after the activities to place Unit 3 into SAFSTOR are complete.
- These tasks are now complete.
O Humboldt Bay 3 SER 4-1
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4.2 Activities During SAFSTOR Period f
During the SAFSTOR period-the major activities by the-licensee at Humboldt Bay Unit 3 are to assure the safety of the spent fuel in the storage pool, to main-tain physical security of the site, to accomplish radiation and environmental monitoring, and to maintain facility structures, components and equipment important to the safe storage of the spent fuel and the residual radioactive material.
Spent fuel will remain in place in the storage pool except for occasional in-spection of a fuel assembly or its Boral can to verify their condition.
The fuel assembly may at that time be lifted out.of the rack to allow visual in-
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spection. All spent fuel handling will be under the direction of a Certified Fuel Handler (SER Section 6.2.2.3).
When the 30 year SAFSTOR phase is complete, the licensee plans to dismantle /
DECON Humboldt Bay Unit 3.
Near the end of the SAFSTOR phase, the li.censee will be required by 10 CFR 50 (Proposed Rule, February 11, 1985) to submit the DECON plan for staff review and approval.
The objective of DECON is to dis-mantle or decontaminate the facility in a way that will ensure the health and safety of the public and maintain occupational exposure as low as is reasonably achievable (ALARA).
The licensee has completed action with the California Public Utilities Commission to set aside and accrue funds for DECON activities (Appendix A).
Humboldt Bay 3 SER 4-2
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i 5 PLANT TECHNICAL SPECIFICATIONS The Technical Specifications (TS) in a license define certain features, charac-teristics, and conditions governing operation of a facility that cannot be changed without prior approval b possess-but-not-operate license.y the NRC. The TS will be made part of the Systems and components-which have been shut down and/or serve no useful purpose.for the SAFSTOR decommissioning mode have been deleted from the TS. Only systems and components required for the storage of spent fuel, for monitoring, for surveillance,'and for the processing of radioactive waste during the SAFSTOR period are covered by TS.
Evaluations of specific TS are included in Sections 4 through 11. 1The TS proposed by the licensee (Shiffer, March 13 and May 23, 1986 and March 20,1987) have been i
review ~ed by the staff and have.6een found acceptable.
The TS specify facility design features for the refueling building, spent fuel pool, refueling building ventilation system, pool service system, fire protec-tion systems, electrical systems, and waste disposal systems. Operating limits also are included for each of the above-listed facilities and systems.
Monitoring requirements are specified for stack gas, process water, spent fuel pool level, onsite radiation levels and offsite radiation levels.
Plant organization, offsite organization, reporting requirements, training and audit committee requirements are also specified in the TS.
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6 ADMINISTRATIVE CONTROLS 6.1 Organization and Responsibilities.
The following description and evaluation are based on information contained in the proposed TS, the Decommissioning Plan, and the Quality Assurance Plan.
In.
addition, the staff reviewed and' compared organization and staffing requirements-p i-contained in NUREG-0709, " Safety Evaluation Report-Related to the Renewal of.
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Materials License SNM-1265 for the Receipt, Storage, and Transfer of Spent Fuel Pursuant to 10 CFR Part 72, Morris Operation, General Electric Company,"
July 1981, with the proposed SAFSTOR organizational and staffing structure -
provided by PG&E, In NUREG-0709 the NRC. staff found that the Morris organiza-tion and. staffing were acceptable for a facility involved with spent fuel storage and transfer. Spent fuel storage at'Humboldt Bay Unit 3-is similar to that at the' Morris Operation.
6.1.1 Corporate Organization The corporate organization and line of responsibility for Humboldt Bay Unit 3 are shown on Figure 6.1 (TS.VII B). The President of PG&E, the Chief Operating Officer with overall _ responsibility for the decommissioning process, has the resources within his organization necessary to support these activities.
The Vice President, Nuclear Power Generation (NPG), reports to the President l
and is responsible for the safe and efficient decommissioning of Humboldt Bay l
Unit 3.
The Plant Manager reports to the Vice President, Nuclear Power Genera-tion and is responsible for the conduct of-all onsite activities' related to surveillance and maintenance of Humboldt Bay Unit 3.
The Quality' Control Supervisor reports to the Plant Manager, and is responsible for the quality related day-to-day activities with authority to identify: quality problems, recommend or provide solutions to quality problems, and verify-implementation:
l of solutions to quality problems.
Inspection results are evaluated by the Quality Control Supervisor or designated personnel to assure that-the inspec-tion requirements have been satisfied. The Manager, Quality Assurance, reports to the President and is responsible for assuring 1the QA Program for Humboldt Bay Unit 3-is established and effectively implemented. The Chairman of-the Board and. President have given the Manager, Quality Assurance (1) the-organizational freedom and authority to -investigate any area or aspect-of the Company's operations as necessary to identify and define-problems associated with the establishment or execution of the QA Program, and (2) the authority to recommend solutions for such problems and to verify that effective, correc-tive action ~1s taken in a timely manner. The Manager, Quality. Assurance,.has the responsibility to prepare, approve, and issue quality assurance procedures, to conduct audits, and the au;hority to stop work should there be a serious breach of any.part of the QA Program.
The Vice President, Nuclear Power Generation, leads the Decommissioning Project-Team for Unit No. 3 (Figure 6.2).
He is the Corporate Officer.who has been designated as the Approving Officer for the Unit No. 3 SAFSTOR' decommissioning project.
It is the Approving Officer's responsibility to approve the project Humboldt Bay;3 SER-6-11 u
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ASSURANCE GENERATION PLANNING AND CONSTRUCTION DEVELOPMENT I
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VICE PRESIDENT NUCLEAR POWER GENERATION DEPARTMENT HBPP PLANT MANAGER DECOMMISSIONING '
PROJECT MANAGEP DN SITE PROJECT TEAM GENERAL 0FFICE PROJECT SUPPORT SUPERVISOR OF OPERATIONS
- SENERAL OFFICE COORDINATOR SUPERVISOR OF MAINTENANCE
- NUCLEAR PLANT OPERATIONS DEPARTMENT SR. CHEM. & RADIATION PROTECTION ENGINEER
- LICENSING SR. POWER PRODUCTION ENGINEER
- NUCLEAR SERVICES DEPARTMENT QUALITY CONTROL SUPERVISOR
- QUALITY ASSURANCE DEPARTMENT ADMINISTRATIVE SUPERVISOR
- ENGINEERING DEPARTMENT l
DiCOMMISSIONING PROJ8CT TEAM ORGANIZATION Figure 6.2 Humboldt Bay 3 SER 6-3 4-
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J scope, schedule.and budget..This Vice President is also the' Chairman:of the.
General Office Nuclear Plant Review and Audit Committee (GONPRAC). The Commit-tee is responsible for the. review of the Decommissioning Plan, proposed license amendments, and proposed changes to the Unit No. 3 Technical Specifications.
In addition, this Vice President directs'the activities of the Decommissioning.
Project Manager and Plant Manager who are' located at.Humboldt.8ay Unit 3.
~
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The~ staff concludes that PG&E has an acceptable corporate organization to support SAFSTOR -status for-Humboldt-Bay Unit 3.
6.1.2 Operating Organization j
6.1.2.1 Project Manager The Decommissioning Project Manager'is located at HBPP..For-the purpose of 1
project management, the Project Manager reports directly to-the Vice President, NPG, although he will keep the Plant Manager. informed of decommissioning activities.
It is the Project Manager's responsibility and authority to-develop and implement a project plan to ensure that.the decommissior,ing project-
~
is completed on schedule, within the approved budgets, and that the results are consistent with the project' objectives.. The Decommissioning Project Team also-incorporates the On-Site Project Team and the General Office Project Support.
The Project Manager is responsible for the On-Site Project Team consisting of:
key supervisors who. supervise the. actual-performance of the decommissioning activities. This On-Site Project Team consists of the Supervisor of Operations, Supervisor of Maintenance, Senior Chemical and Radiation Protection Engineer,-
Senior Power Production Engineer, Quality Control Supervisor and'the Administra-tive Supervisor. They are responsible for assisting the Project Manager in the i.
development-of the project plans, schedules, and procedures. They are also responsible for keeping both the Plant Manager and. Project Manager informed of the status of decommissioning activities for which they are responsible. The d
C Project Manager will also be supported by the General Office Project Support.
This group will be located at the corporate office in San Francisco, California-and consists of a General Office Coordinator, Nuclear Plant Operations-Depart-l ment, Licensing, Nuclear Services Department, Quality Assurance Department, and' Engineering Department.
6.1.2.2 Plant Manager i
The Plant Manager is also responsible to the Vice President, Nuclear Power Generation.
It is the Plant Manager who has the overa11' responsibility for the operation-and maintenance of Unit No. 3, which includes SAFSTOR activities. The Plant Manager and his staff (refer to Figure 6.3)-are responsible 'for all. three generating units at the Humboldt Bay Power Plant (TS VII-C).
i 6.1.2.3 Plant Staff Qualifications 1
Minimum qualifications for members of the plant staff, as specified in Sec-tion VII.C.2 of the TS, are the following:
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-Plant Manager
. -(1) Ten years of responsible -power. plant experi Ance, o'f which one year.-
shall be nuclear power plant experience. A maximum'of four years of
. the. remaining nine years of. experience may be fulfilled on a one-to-one' time basis by academic training in.an engineering or scientific-field generally associated with power production.
(2)- Certified. Fuel Handler.'in accordance with the Humboldt Bay Power.
Plant (HBPP) Certified Fuel Handler Training Program.
b.
Supervisor of Operations.
(1) Eight years of responsible power plant experience, of which one year' shall'be nuclear power plant experience. A maximum of four. years of experience may be fulfilled on a one-for-one time. basis by academic training.in an engineering or scientific field generally associated with power production.
.(2) Certified Fuel Handler in accordance with the HBPP Certified Fuel Handler Training Program.
c.
Power Plant Engineer (Technical Manager) i (1) Bachelor's degree or the equivalenttin' an _ engineering or scientific
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field.
(2) Four years in responsible positions related to power generation, of which one year shall be nuclear industry experience.
(3) Thorough knowledge of radiation and criticality safety requirements and practices, including safety requirements specifically related to maintenance and operations under radioactive contamination conditions.
(4) Certified Fuel Handler in accordance with the HBPP Certified Fuel Handler Training Program.
d.
Senior-Chemical and Radiological Engineer.(Radiation' Protection Manager)
(1) Bachelor's degree or the. equivalent. in engineering or. a scientific field including some formal training in radiation protection.
(2) At least five years of professional experience in applied radiation protection. (A master's degree may-be considered equivalent'to one year of. professional experience and a doctorate may be considered equivalent to two years of professional experience where course work' related to radiation protection is involved.): At least.three years of.this experience should be in: applied radiation protection. work in -
a nuclear. facility ~ dealing with radiological problems similar to-those-encountered in nuclear power stations.
(3) Specialized knowledge of health physics, thorough knowledge-of radia.
tion and criticality requirements and practices, knowledge of.related regulatory requirements and practices.
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Supervisor of Maintenance-
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(1)~ Seven~ years of: responsible power plant experience orLapplicable
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industrial experience, of which.a minimum of one year shall-be:nu-clear power plant experience. 74 maximum of two years of the' remain-ing ~six years of power plant or industrial experience may be ful-filled-by ' satisfactory' completion of academic or related technical-training on a one-for-one basis.
(2) Thorough knowledge _of' safety requirements'specifically related to'-
maintenance of-operations under radioactive contamination conditions.
f.
' Quality Control Supervisor
.(1) Five years-of responsible power plant experience or applicable indus-trial experience, of which a minimum of one year'shall be experience in the nuclear field. A maximum of;two' years of the remaining four 4
years of power plant or applicable industrial experience may be fulfilled by satisfactory completion of academic or related technical training on a one-for-one time basis.
(2) Thorough knowledge of nuclear materials handling,' safeguards, and 4
l quality assurance methods and procedures.
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l (1) High~ school diploma or equivalent.
4 (2) At least four years of power plant experience including at.least one year of nuclear power plant experience.
(3) Certified Fuel Handler in accordance with the. HBPP Certifie'd Fuel.
Handler Training Program.
h.
Certified Fuel Handler (1) High school diploma or equivalent.
(2) At least one year of experience at HBPP.
(3) Satisfactory completion of H8PP _ Certified Fue'l Handler Training Program.
NOTES:
1.
Nuclear experience includes experience at'HBPP operations or during the SAFSTOR period.
2.
An individual may be assigned to any of.the above positions with'-
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out meeting the above requirements.if' sufficient number of other persons who meet-those requirements are assigned to the plant on a full-time basis to assist-the : individual until the minimum qualifications are met.
The Plant Manager also has responsibility for the. Fire Protection : Program l(TS VII-C.3).. A member of the' Engineering Department is appointed by the Plant i
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s Manager to be Fire Marshall. Responsibilities of.the Fire Marshall include periodic evaluation of equipment provided for fire fighting, brigade training, and maintaining a current and effective fire protection program. The Fire Marshall is qualified in fire prevention, and has received formal training in fire. suppression methods. ' The : individual is. familiar with the ' plant's fire protection system and the function of plant equipment and systems. -A minimum-
'of three trained fire brigade members are required to be on site.
In addition, the Fire Marshall maintains a working relationship with and acts' as a liaison to off-site fire protection organizations. Joint training programs and periodic fire drills will be coordinated with the appropriate outside f_ ire-fighting'
. organizations.
The Plant Manager is also Chairman of the Plant Staff Review Committee (PSRC).
This Committee has responsibility for review and approval of activities.that affect nuclear safety, including decommissioning activities. As Chairman of the Plant ALARA Committee, the Plant Manager is responsible for ensuring that both Committees fulfill their responsibilities as described in the Unit No. 3 2
Technical Specifications.
6.1.2.4 Operating Shift
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(a) A five person minimum operating-shift organization will be utilized at
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the plant. The Shift Foreman will direct the shift consisting of the Senior Control Operator, Control Operator, Assistant Control-Operator, and at least one Auxiliary Operator.
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(b) At least one Certified Fuel Handler, a member of the shift operating organization, will be on site when fuel is in the Spent Fuel Storage Pool.
The Plant Manager, Supervisor of Operations, Power Plant Engineer (Tech-nical Manager) and Shift Foreman are required to be Certified Fuel Handlers in accordance with the HBPP Certified Fuel Handler Training Program.
NRC Licensed Reactor Operators (R0s) and Senior Reactor Operators (SR0s) will not be required during the SAFSTOR period since there will be'no fuel in the reactor. However, during the SAFSTOR period, spent fuel may be moved within the spent fuel pool for inspections of the fuel or Boral cans. Also, at some time during this period, fuel handling may be performed to transfer the spent fuel assemblies to shipping casks for shipment-to a permanent Federal respost-tory. Therefore, a training and certification program _will be implemented to maintain a staff properly trained and qualified to maintain the spent fuel, to j
perform any fuel movements that may be required, and to maintain Unit 3 in accordance with the possess-but-not-operate license. This program will provide the training, proficiency testing, and certification of fuel handling personnel.
l
- Spent fuel shall be only handled under the following conditions:
All handling will be accomplished using procedures approved by the Plant Staff Review Committee.
Spent fuel handling-operations shall'be under the direct supervision-of,a member of the plant management staff who is a Certified. Fuel Handler.
At least one Certified Fuel Handler shall be present at the location of each fuel movement.
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During periods of routine SAFSTOR operation, it is expected that the Unit No. 3 control room will not be continuously manned. Audible and visual annunciation of all Unit No. 3 alarms are required at a continuously-manned control station in Units No. I and/or 2 (TS VII-C.1*C).
It may be a common annunciator for all alarms. The NRC staff concludes this is acceptable because the Unit 1 and 2 control rooms are very close (within 100 feet) of the Unit 3 control room.
- The NRC staff concludes that plant staffing and qualifications as discussed above and required by the TS are acceptable to safely maintain Humboldt Bay Unit 3 in a SAFSTOR status. Security staff requirements and the Physical Security Plan were approved on February.11,1987 by Amendment No. 22 to license No. OPR-7.
6.2 Training The licensee's training programs for Certified Fuel Handlers and non-licensed plant staff were reviewed using the proposed Technical Specifications and Decommissioning Plan provided by PG&E. The staff acceptance criteria. included applicable portions of 10 CFR Part 72 Subpart I for Independent Spent Fuel Storage Facility Personnel, and the NRC's Nuclear Materials Safety and. Safe-guards General Plan for Operator Certification under 10 CFR Part 72.
6.2.1 General Employee Training
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6.2.1.1 Description of Plant and Facilities Three levels of training are available.
Level 1, " Plant Orientation," training is given to all new employees and vist-tors. The training provides orientation of site restrictions and rules, and includes an overview of the structures, allowable entry areas, escorted access, security areas, inadvertent entry and alarms, and radiation hazards.
Level 2, " Power Plant Overview," discusses power plant operation, system compo-nents, and auxiliary systems. Activities impacting health and safety are dis-cussed to develop the background for emergency planning and radiation protec-tion training. Level 2 training is given to all new permanent plant staff in addition to the Level 1 training described above. This training provides more detailed information regarding plant equipment, operation and organization.
Additional activities included in this training are: QA/QC; radiation protec-tion; emergency plan training; security plan training; and fire brigade intro-duction.
If appropriate, material safety and hazardous materials management is also included as part of the Level 2 training.
Level 3, " Detailed Description of Plant Systems," training is detailed technical training reserved for workers engaged in operation, maintenance, or testing of
. systems. Level 3 training also includes any annual retraining and requalifica-tion requirements.
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d 6.2.1'.2 General Site-Rules This section discusses plant policies.on health-and safety,_ vehicle operation, firearms, liqbor and drugs, cameras and other personal items, as well as any disciplinary actions which may be accorded to policy violations.
6.2.1.3 Radiation Protection Program Radiation workers complete a training course'_that provides classroom instruction and practical _ demonstrations to permit them to. perform their work in anfeffi-cient, safe manner. Topics include:
radiation types, exposure, and biological effects; health protection problems, ALARA philosophy and program, and NRC rules-and regulations; exposure reports, protective devices,' routine radiation work permits, and special work permits; and high hazard' areas, contamination, and decontamination. Training is based upon 32 key questions identified in Regula-tory Guide 8.29, " Instruction Concerning Risks From Occupational Radiation Expo-sure." An examination is administered with a minimum passing grade of 70%.
t Nonradiation workers are provided fundamental information on radiation,~ health effects, and risks.
All employees who routinely work in the radiologically controlled areas of the plant, and transient workers whose work may involve significant radiation expo-sure are classified as radiation workers, and will participate in the radiation protection program. Radiation protection training will'be commensurate with an individual's work requirements and the areas to which they are permitted access.
Nonradiation workers (i.e., persons whose work rarely, if ever, requires they enter a radiologically controlled area and/or who receive minimal radiation
-exposure) shall be provided with fundamental training on radiation, health effects, and risk as appropriate.
Members of the Radiation Protection Department (as described in Section 6.0 of the SAFSTOR Decommissioning Plan, Schuyler,1984) and Certified Fuel Handlers are responsible for implementing the requirements of the Radiation Protection Program. These individuals, as part of their initial qualification, will receive additional training in radiological work practices and the use of specialized survey and analysis equipment to the extent necessary to perform their duties.
6.2.1.4 Respiratory Protection Individuals required to wear respirators are medically qualified, fit tested, and trained in the proper care and use.of respirators. - All Operations Department personnel and members of the maintenance department and plant management staff, who may be required to enter an area where the use of-respiratory protection equipment is necessary, must have knowledge of respirators. When negative' pres-sure respirators are used, training includes qualitative fit testing.
Indivi-duals are acquainted with OSHA, Cal OSHA, NRC, and ANSI requirements for-respirators, their use, and when they should be used.
6.2.1.5 Site Emergency Plans The emergency plan describes the licensee's program for training plant person-nel in emergency response duties. The extent of the training is dependent on i
an individual's assigned responsibilities but all personnel receive basic Humboldt Bay 3 SER 6-10 E
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instructions in the fundamentals of the emergency plan.
Training is provided in emergency procedures, emergency radiological monitoring, generalLradiation protection, fire-fighting and first-aid.
Training for offsite agencies is provided.primarily-by the agencies themselves.
Contact is made on a routine basis with the Sheriff's Department, Fire District No.1, and St. Joseph and General Hospitals to reaffirm the. arrangements _in the i
plan.
If requested, PG&E personnel are prepared to provide training on radiation protection and other emergency plan topics to offsite response. personnel.
6.2.1.6 Industrial Safety, First Aid, and Fire Protection PG&E's Accident Prevention Program provides basic instruction in these topics.
Persons having unescorted access to Unit No. 3 must know the significance of barrier tapes and equipment status. tags and must be familiar with fire prevention and fire fighting techniques.
Individuals are taught to use water and CO 2 sys-tem extinguishers and fire brigade equipment.. A fire brigade training program is provided to fire brigade members for more extensive practical training.
s I
6.2.1.7 Security Program Individuals granted unescorted access to Unit No. 3 are required to understand the security program including badging, procedures for entering-secure areas, measures to avoid causing security alarms, recognition and reporting of un-authorized personnel, and searching policy (TS VII.E.1.f.).
6.2.2 Technical Training In addition to General Employee Training as discussed above, some workers are provided with more extensive technical training appropriate for their work assignments. As an example, hazardous material and waste handling training is provided when necessary to supply information on waste management, environmental protection, safety standards, and personnel protection.
4 As discussed in the SAFSTOR Decommissioning Plan, each person employed at Hum-boldt Bay Unit 3 will receive general employee training.
In addition, special training will be provided as needed when it is deemed necessary or prudent to assist employees involved with unusual or infrequent procedures associated with decommissioning activities. Special training relating.to decommissioning activ-ities may include such topics as radioactive waste volume minimization, handling of contaminated materials, and decontamination workers'. training. - Employees actively involved with such activities will receive special training appropriate to their job duties and responsibilities as necessary and on a timely basis.
6.2.2.1 Radiation Protection Department Training Program Radiation Protection " Professionals" are given -comprehensive' training in radi-ation protection, covering theory and practical experience with equipment at a technical level beyond General Employee Training-(TS VII.C.4.d). The term
" radiation protection professionals," as referred to on page 4-17 of-the SAFSTOR Decommissioning Plan (Schuyler,1984) includes the following positions: Senior Chemical and Radiological Engineer; Radiation and Process Monitor Foreman; and Radiation and Process Monitors.
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41 Individuals in these positions are responsible for.the implemen'tation and day-to-day work associated with the Radiation Protection Program. Persons in these positions have prior training / experience in the radiation protection field and/or receive extensive training *in-the radiation protection procedures and-work practices at Humboldt Bay Unit 3.
A comprehensive program is presented'to HBPP Radiation and Process Monitors
-(RPMs). Radiation and process. monitors are_the employees who perform chemical and radiological sampling analyses and radiation and contamination surveys.
In addition, they implement the personnel radiation monitoring program, maintain.
radiation protection records, and provide monitoring for work in radiologically controlled areas. Two such positions will normally be filled during SAFSTOR.
.The training consists of academic classroom training,-on-the-job training,'and i
retraining to implement changes'and improve skills. The course requirements-(TS VII.C.4.d) include:
Nuclear Technology - basic nuclear. and radiation protection theory-
-Plant Design and Operation plant layout, system functions, and equipment-Chemistry - analyses, calibration, and instrumentation Radiochemistry - sample preparation, counting, data reduction and use and maintenance of instruments Emergency Plan and Procedures - emergency responsibilities, surveys, analy-sis, radiation protection during accident conditions, and environmental monitoring.
Radiation-Protection - in-depth training is presented.on atomic theory, radioactivity, properties of radiation types,-units and dose, biological effects, standards, detection, dosimetry, instruments, personnel monitoring, air sampling, instrument operation, counting statistics,_ internal dose calculations, shielding exposure control, surveys, respiratory protection,_
and decontamination methods 6.2.2.2 Use of Monitoring Equipment RPMs are provided with on-the-job training to enhance skills for operating var-tous types of radiation detection equipment. In addition to the use ofLsampling equipment with sampling trains in-line, RPMs are taught how to use portable monitoring equipment such as Cutie Pies, GM detectors, alpha detectors, and dual channel continuous air monitors.
Information discussed includes the-proper use of probes,. read-out evaluation,fsurveys and data to_befcollected, instrument response time,. efficiency, and modes of operation. As part of the RPM's periodic retraining, proficiency regarding monitoring equipment will be verified every two years unless _ new equipment or procedural changes dictate.a more frequent ~ proficiency check.
Humboldt Bay 3 SER 6-12
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6.2.2.3. Certified Fuel Handlers
- 6.2.2.3.1 Training and Certification Requirements for! uel Handlers F
NRC' Licensed Reactor Operators (R0s).and Senior Reactor Operators 1(SR0s) will l
not be required during SAFSTOR as there willLbe no fuel in-the reactor.. How--
ever, because there.will be fuel in the spent fuel (storage pool, a training and
. certification program for Fuel Handlers will be implemented to maintain a staff '
j properly trained and qualified tol maintain the spent fuel, to' perform any fuel
-l movements that may-be required,'and to maintain Humboldt Bay Unit 3Ein accor-dance with a possess-but-not-operate license. 'This program will provide the training, proficiency testing, and certification of fuel handling personnel as required by TS II.C.4.
Thefollowingmembersoftheplant' staff (asaminimum)Lshallbecertifiedin accordance with this program:
Plant Manager.
Power Plant Engineer Supervisor of-Operations Shift Foreman Selected operators who shall be performing duties requiring Certified Fuel Handlers Training Coordinator Upon successful completion of this program, the employee will be certified by the Plant Manager or his delegate as a Certified. Fuel Handler.
6.2.2.3.2 Training Program for Certified Fuel Handlers
!.i Certification candidates shall participate in training program covering the following topic areas: (TS VII.C.4.2)
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(1) Reactor Theory (as applicable to the storage and handling of spent reactor _
fuel)
(2) Spent Fuel Handling and Storage Equipment - Design and Operating-Characteristics (3) Monitoring and Control Systems (4) Radiation Protection (5) Normal and Emergency Procedures (6) Administrative Controls applicable during the SAFSTOR' period Training will be provided through a combination of classroom instruction, audio-visual instruction, self-study, and on-the-job training.
Initid1_ certification training will be approximately 50% classroom instruction or supervised self-study with an instructor available to monitor. progress' and answer questions.
The remainder of the initial certification training; program will be on-the-job training.
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i Satis' factory completion of the training shall be based on _ passing of a compre-hensive written-examination including each of_the above areas and an oral exam-ination. _ The Certified Fuel Handler candidate must score at least 70Lin each
' area. The candidate must attain an overall average: store of'at-least 80L. The
- oral examination shall be administered-by a' member of ~the plant management staff.
Results of the oral examination shall be'on a pass / fail basis.' Any. weaknesses i
noted as a result of;the written or oral examination shall be documented, and-l remedial training provided.
Initial Certification and Proficiency Training shall be documented and main-tained for certified personnel for.a minimum of five' years. The records shall include the data'and periods of training,.results of all quizzes and examina--
tions, copies of written. examinations, oral examination records, and information on results of physical examinations.
I The staff concludes that the Training and Certification Program for' Fuel Handlers provided by PG&E is comparable to the NRC General Plan for Operator Certification i
_under 10 CFR Part 72 and is acceptable.
f 6.2.2.3.3 Certified Fuel Handler Requalification Training Progra'ms After initial certification, personnel wi_Il be recertified every two years based on the successful completion of the Proficiency Training and Testing Program (TS VII.C.4.b).
Proficiency training shall be used to maintain the qualification level of cer-i
- tified personnel, and will include periodic training through the use of classroom training, audio / visual instruction, self-study assignments, and/or on-the-job.
training. Proficiency training for certified fuel-handlers will be accomplished 1
i:
through a preplanned lecture series which will be primarily classroom training and on-the-job self-study assignments.
Frequency-and topics to be included in.
the proficiency training will depend on actual Unit No. 3 activities planned or j
in progress and identified weaknesses. The frequency of proficiency training shall be such that all six of the topics discussed in the Decommissioning Plan are covered in a two year period..If, in the course oflthe annual. training,
).
an infrequently performed activity or. procedure is planned for which training should be conducted, it may be moved from its regularly scheduled time to accom-t modate the present circumstances. This training will be_in addition to any 1
previously scheduled topic. Additionally, any significant areas'of weakness noted on the annual exams shall be given priority in the training schedule.
2 -
Recertification testing shall cover all six areas of the initial certification.
The emphasis will be placed on topics taught since the last annual-examination and on current conditions at the plant.
An annual written examination and an annual oral examination shall be used to demonstrate the proficiency of certified personnel. Examinations will be simi-lar to but not as comprehensive as the initial' certification examinations. The j
recertification candidate must score at-least 70%.in each section. The: candidate must attain an overall_ average score of at least 80L Oral examinations shall be on a pass / fail basis. The staff concludes that the licensee's recertifica -
tion program for Fuel Handlers is acceptable, and meets the objectives of ANSI N18.1-1971 to provide a training program which maintains the proficiency of the j
operating organization.
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t 6.2.2.4 Quality Assurance / Control Program Individuals who perform quality-related work receive training in the use of l procedures, the documentation.of work, discrepancy reporting, and the role of
. Quality Control Inspectors.
Initial training of. Level III Quality Control (QC) Inspectors (supervisors) and Level II QC Inspectors (journeymen) is provided by the QC Supervisor. This instruction is supplemented by a review of plant procedures and the use of videotapes.
Refresher training for QC Inspectors is provided annually and may include any of the following:
Procedure review with emphasis on new or revised procedures Classroom training utilizing videotape and/or lectures
-Participation in specialized training offered outside PG&E i
Additionally, the Plant Quality Assurance Department provides annual training for Level III QC Inspectors.
The PG&E Quality Assurance Program is evaluated in Section 6.3.
6.2.3 Other Decommissioning Training It is anticipated that other technical topics will be presented to personnel on an as-needed basis. The need for training is determined based on the potential for: personnel injury; spread of contamination; high radiation exposure; or if-the procedure is performed infrequently. Current administrative guidelines will be followed to establish new procedures and to ensure the training is com-pleted. Suggested topical outlines are presented below for two such sources.
6.2.3.1 Radioactive Waste Volume Minimization The course will identify the methods and techniques of achieving the following
~
goals:
i Liquid radioactive waste control Control of material entering radioactive materials area Contamination control Waste segregation program Radiological work planning 6.2.3.2 Decontamination Workers Decontamination. workers will be instructed in the methods, applicability, and techniques for decontamination. The areas of discussion and demonstration include:
Categories of processes:
Chemical decontamination Manual and mechanical decontamination Electropolishing Humboldt Bay 3 SER 6-15
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Ultrasonic decontamination Decontamination effectiveness (Decontamination Factor-DF)
Processing requirements Solvent / system interactions Equipment Surface decontamination of concrete structures 6.2.4 Training Program Administration and Records The HBPP Manager is responsible for ensuring that the training requirements and programs are satisfactorily completed for site personnel. The HBPP Power Plant Engineer is responsible for the organization and. coordination of training programs and for ensuring that records are maintained and kept up to date (TS VII-I.2.1). The HBPP Training Coordinator is responsible for maintaining the records and assisting.in training material preparation and classroom instruction.
Training which is required to satisfy a regulatory or procedural requirement will be documented on a Record of Training Sheet and accompanied by an Atten-dance Sheet. The training topic will be identified on the record sheet and any applicable training materials will be included or referenced as part of the package.
6.3 Quality Assurance The SAFSTOR Quality Assurance Plan (QA Program) for the decommissioning of Hum-boldt Bay Plant Unit 3 is described in the enclosures to the December 13, 1985 and March 14 and May 23, 1986 letters from J. D. Schiffer to H. N. Berkow.
The staff evaluated this plan to assure it meets the necessary provisions of 10 CFR 50, Appendix B to the extent consistent with tre importance of the decommissioning activities to safety (TS VII.D.2.h.(4)).
6.3.1 Organization The structure of the organization responsible for the decommissioning of Humboldt Bay Unit 3 is shown in Figures 6.1 and 6.2.
Refer to Section 6.1.1 and 6.1.2 for corporate and plant staff.
6.3.2 Quality Assurance Program The Humboldt Bay Unit 3 QA Program applies to:
1.
Radiological monitoring of gaseous and liquid effluents and environment.
2.
Packaging and transport of radioactive material.
3.
Implementing plant Technical Specifications.
4.
All personnel involved in the Humboldt Bay Unit 3 SAFSTOR activities.
The QA Program of the decommissioning of Humboldt Bay Unit 3 describes the qual-ity assurance policies, goals, objectives, and requirements to be implemented at the plant to assure that decommissioning activities are performed in a con-trolled manner and documented to provide objective evidence of compliance. The QA Program is implemented by procedures, instructions, and drawings. The QA organization reviews and concurs in the procedures and instructions for Humboldt Bay 3 SER 6-16
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- implementing the QA Program. In addition, the' QA Program provides a: commitment-to comply.with the NRC Regulatory Guides'1.88, Revision 2, 1.144'andLI.146.
The-QA Program requires that' quality assurance documents provide controls' for:
(1) prescribing. quality-affecting activities'by documented procedures, instruc-tions', or drawings; (2) issuing and distributing approved documents;;(3) per-i forming surveillances, te'sts and inspection activities;-(4) identifying and dis-positioning nonconforming items; (5) initiating appropriate corrective _ actions;.
(6) preparing and maintaining quality assurance records; and (7)-auditing-activities that affect quality.
The QA Program requires the establishment and implementation.of a quality assur-ance indoctrination, training, and retraining program to ensure that persons
-involved within the. scope of decommissioning activities are appropriately qualified.
Quality is verified and-accomplished by personnel within the Quality _ Assurance l
organization who do' not have direct responsibility for performing the work being verified,'or by personnel trained and qualified in quality assurance practices and concepts and are-independent of the task being inspected.
l Additional quality assurarce controls for review, auditing, testing, surveillance and radiological monitoring are included in the TechnPal Specifications.
j The Manager of Quality Assurance is responsible _for auditing' the implementation t
i of the QA Program. Audit results are required to be documented and the managers having responsibility _in the area audited are required to review these results to determine and take appropriate corrective action. The Manager of Quality Assurance reviews and evaluates these results to assure that corrective action is taken for adverse findings.
6.3.3 Quality Assurance Conclusions On the basis of its review and evaluation of the Humboldt Bay Unit 3 QA Program, the staff concludes that:
1.
Quality assurance personnel have sufficient independence from cost and schedule and the necessary authority and access to an. upper level of.
management to effectively carry out and perform the_ quality assurance-functions.
2.
The QA Program describes requirements, procedures, and control that, when
-properly implemented, comply with the provisions of 10 CFR 50, Appendix B, to an extent commensurate with the safety functions to be performed by facility structures, systems and components during decommissioning activities.
Accordingly, the staff concludes that the licensee's Quality' Assurance Program is acceptable and gives reasenable assurance that the decommissioning activities-will be conducted in a controlled and acceptable manner.
Humboldt Bay 3 SER 6-17 a
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m 7 OCCUPATIONAL HEALTH AND SAFETY The staff has reviewed the licensee's planned management responsibilities and commitments..The health physics program, including procedures, equipment, in-strumentation, training and personnel dosimetry, were evaluated. The acceptance 4
criteria used by the staff are stated in NUREG-0800, and Regulatory Guide 8.8, 4
Revision 3 (TS VII.J).
7.1 Health Physics and Safety Management The licensee has formed a deccanissioning project team to establish the custo-dial SAFSTOR conditions for Humboldt Bay Unit 3.
The. purpose of this project team is to ensure the SAFSTOR project is planned, scheduled and coordinated within various departments of PG&E. The decommissioning team will use the Plant Staff Review Committee (PSRC) to review and approve all activities that affect nuclear safety. The Humboldt Bay Radiation Protection Manager'(RPM) is a member of the PSRC (TS VII.0.1.b).
In accordance with the plant's Technical Specifications, the Plant Manager will continue to have overall responsibility for the safe operation of required equip-ment at Humboldt Bay Unit 3.
This responsibility will continue during prep-aration for, and during SAFSTOR activities.- He will act as chairman of the PSRC and the plant's as-low-as-is-reasonably-achievable (ALARA) committee (TS VII.D.1.b.).
The Senior Chemical and Radiological Engineer is the RPM at Humboldt Bay Unit 3.
His qualifications meet the requirements of Regulatory Guide 1.8 (Revision 1-R).
His duties include supervising the activities of the health physics group, as well as implementing and enforcing the plant's health physics progra,m.
In addi-l tion, the plant RPM is responsible for assuring that contract personnel have l
sufficient training and experience in plant radiation protection procedures to i
ensure that their doses are ALARA.
The RPM reports _directly to the Power Plant Engineer, but has the authority to report health physics matters to the plant's manager or any other level of PG&E he deems appropriate.
The staff finds the plant health physics management meets the acceptance criteria of NUREG-0800, and Regulatory Guide 8.8 (Revision 3) and is acceptable.
7.2 Radiation Sources The spent fuel assemblies in the spent fuel pool contain the-largest source of radioactive material. The next large source is the reactor. vessel and in-ternals.
Radionuclides are also present in corrosion films within various in-plant reactor systems (e.g., reactor water _ clean-up system).
For radiation protection, the staff finds the plant's spent fuel pool an accept-able location for the spent fuel for;the following reasons:
(1) the poo11was designed to shield freshly irradiated fuel to ALARA levels, and (2) the Humboldt Bay spent fuel has had at least ten years of decay time. Accordingly, the total
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dose to all than one manplant personnel d'e to spent fuel should be very low, i.e., less u
rem per year over the 30 year SAFSTOR period.
The. reactor vessel and vessel internals, as well as the corrosion films within
-various systems, will be secured by the licensee by vari The staff finds that the licensee's plan for controlling sources of radioactivity is acceptable.
7.3 Dose Committment PG&E has estimated that the collective dose equivalent to the plant staff for the 30 years of SAFSTOR followed by delayed DECON is approximately 177 man-rem.
The_ staff considers this to be a reasonable estimate and acceptable, 7.4 Health Physics Program The health physics group currently consists of one Senior Chemical and Radiological Engineer, one Chemical and Radiological Engineer, a Foreman and a staff of Radiation and Process Monitors (Technician).The number of health physics personnel will vary depending on the amount of work activity being per-formed within the plant.
The licensee has committed to using contract personnel using current plant hiring procedures when additional health physics help is required. The staff finds this to be reasonable and acceptable.
of the health physics group includes performing area and airborne radioactivityRes of radiation protection equipment and instrumentation, perso maintenance of records and reports and other related tasks.
These activities will be performed during the preparation of SAFSTOR and during the 30 year interim period prior to delayed dismantlement. The ultimate goal of the health physics program is to ensure that radiation dose to workers and members of the general public is ALARA.
7.5 Health Physics Instruments, Equipment and Facilities The radiation protection equipment and facilities in place at the Humboldt Bay Unit 3 during SAFSTOR will be similar to that which existed during plant opera-tion. These include a counting room radiation laboratory,' calibration facil-ity, personnel decontamination room a,nd a respirator-cleaning facility.
facilities are sufficient to maintain occupational radiation exposure ALARA These during SAFSTOR.
3 Equipment to be used for radiation protection purposes includes
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portable radiation survey instruments, personnel monitoring equipment, fixed air samplers, respiratory protective equipment and protectiv The number and type of equipment to be used are adequate and provide reasonable ALARA during SAFSTOR. assurance that the licensee will be able to maintain occupatio l
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7.5 Health Physics Procedures During the preparation for SAFSTOR and during SAFSTOR, all plant personnel entering controlled radiation areas, will be assigned personnel dosimeters.
i Humboldt Bay 3 SER 7-2 I
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Whole-body counts of all. plant personnel who enter restricted areas will be conducted on a scheduled basis and other bioassays will be provided when. deemed necessary by the plant's health physics staff, using the guidance of Regulatory Guide 8.26.
All radiation exposure information will-be processed and recorded in accordance with 10 CFR Part 20.
On the basis of the plant's health physics organization, equipment, and proce-dures, and on consideration of relevant staff positions and Regulatory Guides dealing with radiation protection and administrative controls, the staff con-cludes that the licensee intends to implement a radiation protection program during SAFSTOR that will maintain inplant radiation exposures within the appli-cable limits of 10 CFR Part 20 and will maintain exposures ALARA in accordance with NUREG-0800 and Regulatory Guide 8.8 (Revision 3).
Humboldt Bay 3 SER 7-3
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~ 8 FINANCIAL PLAN PG&E.has provided detail on'the method it proposes to accumulate funds both for preparation for SAFSTOR in'the near.ters and for ultimate dismantlement after a 30 year decay period. - The-licensee projects initial SAFSTOR costs ~of $10,000,000, or less, and annual maintenance and monitoring costs of $650,000 until. dismantle-ment commences. -The licensee and the Public Utilities Commission of the State of California (CPUC) estimated the cost of decommissioning Humboldt Bay Unit 3 to be $42,000,000 in 1981.~ If escalated to 1986 dollars, the cost increases to
$58,000,000.
PG&E proposed to. amortize-the cost of dismantlement:over a 15 year period.. The CPUC ruled on December 4, 1985 (See Appendix A) that the decommis-i sioning fund shall be collected over a four year period, coinciding with the four year amortization period adopted for recovery of the decommissioning expense.
Proceeds from the-amortization will be deposited in a trust fund account not controlled by the licensee, as provided by CPUC rulings, and allowed under proposed NRC decommissioning regulations in 10 CFR 50.33(k).
The staff concludes that the PG&E funding plan provides adequate assurance that sufficient funds will be available to complete the decommissioning of Humboldt Bay Unit 3.
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RADIOACTIVE WASTE MANAGEMENT
'-9.1 Liquid and Gaseous Waste Management Systems 9.1.1 System Description and Review
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Radioactive liquid waste generated during the SAFSTOR. period will be processed r
and disposed.of. The expected sources of radioactive liquid wastes include spent' fuel pool liner gap,. spent ~ fuel storage pool recirculation pump packing E
' leakage, waste water from ongoing decontamination l activities, hot lab waste,
-and rainwater runoff from contaminated areas.
A building has been erected to enclose tne exposed portions of the radioactive' waste processing system. The building prevents rainfall. contamination-and avoids-the need for processing this contaminated rainfall. During-the SAFSTOR period, the only significant activities will be associated with the operation and main-tenance of the spent fuel storage pool ~and the processing of wastes resulting from the spent fuel storage pool. These activities will account for essentially all radioactive material waste.
The liquid radwastes from the spent fuel pool, decontamination activities, and the hot lab will be collected and sampled.
If contamination is present or sus -
pected in a batch, it will be further processed before discharge to the plant i
discharge canal. Processing consists of filtration and, if necessary, treatment by the radioactive waste evaporator or a demineralizer, depending on chemical composition. After processing, the liquid effluent will be sampled and analyzed prior to release to the plant discharge canal, where it will be diluted with the Unit 1 and/or Unit 2 circulating water before discharge to Humboldt Bay.
1 i-The ventilation exhausts from the refueling building, hot lab, hot machine shop, and the radwaste treatment building operating area will be. routed to the plant ventilation system for release from the 250-ft-high plant stack which has a
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gas monitoring ~ system. No treatment is provided by thi.s system for: normal j'
over the spent fuel storage pool. Controlled ventilation is not provided for releases. A cover with a controlled ventilation exhaustcis being~ installed the solid waste storage vault, the low-level waste storage building, or the solid waste handling building. The vent header which collects all'v'ents from the liquid radwaste treatment facility will be connected to the plant ventila-tion exhaust system to permit monitoring by the stack gas monitoring system.
In the event of working operations such as cutting of radioactive components or i~
an accident which results in-high airborne. particulate radioactive material in-the refueling building, the refueling building ventilation system can be iso-lated, and the refueling building air exhausted through the gas treatment i
system high efficiency particulate air'(HEPA) filter (Shiffer,- February 1985).
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This system consists of the original. gas scrubber column.(with the' original pacliing and scrubber solution removed), demister, HEPA filter'and fan.
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- The operation and maintenance of the spent fuel storage pool and.the process-ing of wastes resulting from the spent' fuel-storage pool has continued through all the years after the plant's commercial operating period, which ended in July 1976. The calculated annual gasecos and liquid effluent releases over the 30 year SAFSTOR period were evaluated using. values given in'the-Humboldt Bay Power Plant semiannual Report (s) on Radioactive Effluent Releases and Waste Disposal covering the post-shutdown years 1977 through 1983. On.the average, actual releases are expected to be less than the calculated releases (listed.
- in Table 9.1 and 9.2) due to radioactive decay over the 30 year period. A mini-mal amount, four microcuries per year, of selected radionuclides are included in the calculated annual releases for conservatism,-although in recent years they have not been detected and are not expected.
Releases of radioactive materials during final decontamination and dismantlement at the end of-the 30 year SAFSTOR period will primarily-be due to waste manage-ment operations. Atmospheric releases will be insignificant.
Releases in liquid.
effluents during the four year DECON period are estimated to be about 0.6 Ci of gross beta gamma and gross alpha emitters and 6 Ci of tritium. Liquid radwastes 4
will be treated as required before release.
9.1.2 Acceptance Criteria In its evaluation of the liquid and gaseous radioactive waste management systems, the staff considered (1) the capability of the systems to maintain releases to unrestricted areas below the limits in 10 CFR 20, (2) the' system design to ensure adequate safety under normal and postulated accident conditions in accordance with 10 CFR Part 50 Appendix A General Design Criteria (GDC) 61, and (3) the design features that are incorporated to control and monitor the releases of radioactive materials in accordance with GDC 60 and 64.
9.1.3 Evaluation Findings The staff concludes that the design of the liquid and gaseous radioactive waste management systems are acceptable and meet the requirements of 10 CFR 20.106 and GDCs 60, 61 and 64 because the systems are designed to:
(1) assure that the concentrations of radioactive materials in liquid and gaseous effluents released to unrestricted areas will be less than the limits of 10 CFR 20, Appendix 8, Table II, Column 2, and (2) assure that releases are adequately 4
monitored.
9.2 Solid Waste Management Systems 9.2.1 System Description and Review The liquid radioactive waste concentrated by the evaporator will be accumulated in the concentrate waste tanks until one tank is filled. The concentrated liquid waste then will be analyzed and solidified by an outside contractor using portable equipment. Spent cartridge-type filters and filter crud will be pack-aged in drums and stored in a shielded area. When a sufficient quantity has been accumulated, the wastes will be analyzed and processed by solidification /
encapsulation by an outside contractor using portable equipment. Dry radio-active waste and contaminated tools, equipment, lumber and soil will be packaged for shipment and stored until shipping for disposal. Handling of activated components will be similar to handling of spent filter or dry radioactive waste, Humboldt Bay 3 SER 9-2
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Table 9.1 C'lculated releases of radioactive materials in liquid a
effluents from Humboldt Bay Unit 3 during the 30 year SAFSTOR period Nuclide-mci /yr Nuclide mci /yr-Corrosion and activa' tion products:
Fission products continued
- l Cr-51 0.004 I-131' O.004 -
4 Mn 0.4
- Xe-133 0.004 1
Co-58 0.004 Xe-135 0.004 Co-60 28 Cs-134 11 Zn-65 0.4 CS-137
~ 110 Zr/Nb-95 0.004 Ba/La-140 0.004 Np-239 0.004 Ce-141 3.2 Ce-144 4
Fission products Others i
Sr-89 0.004
- 1 Sr-90 0.3 Tritium 83 Mo-99 0.004 Gross alpha 0.42 Tc-99m 0.004 i
a Table 9.2 Calculated releases of radioactive materials in gaseous i
and particulate effluents from Humboldt Bay Unit 3 during-the 30 year SAFSTOR period Nuclide mci /yr Nuclide sci /yr Kr-83m 0.004 I-133 0.004 Kr-85 0.920 I-135 0.004 Kr-85e
.0.004 i
Kr-87 0.004 H-3 40 Mn-54 0.019 Kr-88 0.004 Co-60 0.220 Kr-89 0.004 Sr-89 0.004 Xe-133 0.004 Sr-90; 0.0081 Xe-133m 0.004 Sb-125 0.0047 l
Xe-135 0.004 Cs-134 0.014 I
Xe-135m 0.004 Cs-137-0.061 l
Xe-137 0.004 Ba/La-140 0.004 Xe-138 0.004 Ce-144 0.025 I-131 0.004 Gross alpha 0.004 i
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as appropriate. After processing and handling as.above, all solid wastes will be stored on-site until shipped in appropriate containers for disposal at a licensed disposal site. The solid waste vault, the low-level waste storage building, and the solid waste handling building will be utilized for the storage of solid wastes prior to shipment for off-site disposal.
A process control program will be used in processing wet radioactive wastes to meet shipping and burial ground requirements.
9.2.2 Acceptance Criteria In its evaluation of the solid radioactive waste management system, the staff
' considered:
(1) the provisions for the processing and packaging of wastes relative to the requirements of 10 CFR 20, 61 and 71 and applicable Department of Transpor-tation (DOT) regulations; and (2) provisions for onsite storage before shipment.
9.2.3 Evaluation Findings The licensee has estimated that, on the average, approximately 1 m' (36 ft')
of resins containing 0.1 Ci of radioactivity, 2 m' (75 ft') of evaporator bottoms containing 0.01 of Ci of radioactivity, and 4 m (150 ft') of dry 2
radioactive wastes containing 0.0015 Ci of radioactivity (mainly Cs-137 and Sr-90) will be generated annually to be processed, stored, and shipped offsite to a licensed disposal site. The packaging and shipping of all these wastes will be in conformance with the applicable requirements of 10 CFR 20, 61 and 71 and 49 CFR 170 to 178.
Concentrated liquid radioactive waste will be processed by solidification by an outside contractor and spent cartridge-type filters will be processed by solid-ification/ encapsulation by an outside contractor (Shiffer, February 1985). The outside contractor will use portable equipmer.t for processing the solid radio-active waste. A TS is incorporsted-in the license to require that the solid radwaste system shall be used in accordance with a process control program to process wet radioactive wastes to meet shipping and burial ground requirements (TS VI.B.2.c).
9.3 Process and Effluent Radiological Monitoring and Sampling Systems 9.3.1 System Description and Review The process and effluent radiological monitoring systems are designed to moni-tor radioactivity levels in plant discharges to the environment.
The stack gas monitoring system consists of equipment on each of two sampling streams. Equipment on each stream includes a particulate filter, a sample pumping system, and a gamma monitoring system using a scintillation detector.
The information from the radiation recorders and flow rate indicators will permit evaluation of noble gas stack release rates in the range of 0.0001 to 10 curies per second of Kr-85.
Humboldt Bay 3 SER 9-4
The process water radiation monitoring system employs a scintillation detector and. indicates,-records, and alarms on.high radiation levels in the radwaste discharge line to the circulating water system discharge pipe. A typical sen -
sitivity of the monitor is 200 cpm pdr:pCf/ml for Cs-137 and 450 cpm per pCi/ml for Co-60. The range is 10 to 10' cpm.
Each batch of waste will be sampled and analyzed prior.to release to the discharge canal (TS VI.B.1.d.).
9.3.2 Acceptance Criteria In its evaluation of the process and effluent radiological monitoring and sampling system, the staff considered (1) the provisions proposed to sample and monitor all station' effluents in accordance with GDC 64; (2) the provisions proposed to ensure control over discharges in accordance with GOC 60; (3) the provisions proposed for sampling plant waste process streams for process control in accordance with GDC 63; and (4) the provisions for conducting sampling and analytical programs in accordance with the guidelines of Regulatory Guides 1.21 and 4.15.
9.3.3 Evaluation Findings The staff concludes that the process and effluent radiological monitoring and sampling systems are acceptable and meet the relevant requirements of 10 CFR 20.106 and GDCs 60, 63, and 64.
The process and effluent radiological monitoring and sampling systems include the instrumentation for monitoring and sampling radioactivity in contaminated liquid, gaseous, and solid waste process and effluent streams.
TS have been established which limit release rates for radioactive materials in liquid and gaseous effluents and require routine monitoring and measurement of all principal release points to ensure that the facility is operated in con-formance with the regulations (TS VI.B.1, 2 and 3).
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j 10 - ' POSTULATED ACCIDENTS On July'16, 1985, the NRC issued License Amendment No. 19 to revise License No. OPR-7 to possess-but-not-operate status since all fuel had been transferred to the spent fuel pool. Therefore, only non-reactor accident scenarios need be evaluated. All of the spent fuel,'390 assemblies,-'is stored in the spent fuel 4
pool.
Except for one assembly, which is: stored-in a stainless steel box, Boral=
neutron absorbing blankets surround each fuel. assembly to ensure subcriticality.
4 following any event which could result in a rearrangement of stored. spent fuel assemblies from the existing assembly storage configurations. This review was
- conducted in accordance with NUREG-0612 and NUREG-0554 with respect to accident
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assumptions, and in accordance with the Standard Review Plan.for the Safety:
Review of Nuclear Power Plants (NUREG-0800) Section.9.1.2 with respect to criticality.
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The methodology for analyses of the. radiological consequences of accidents is consistent (if not more conservative) with those used in assessing operating reactor accidents.
For those postulated accidents involving airborne releases, 2
this SER evaluation uses more conservative atmospheric diffusion and transport-assumptions than those used in the FES (NUREG-1166). These more conservative l
assumptions for the SER are consistent with NRC reviews for operating plants.
The SER evaluations for accidents that do not involve airborne releases are i
identical to FES (NUREG-1166) evaluations.
i For evaluation of offsite radiological consequences of potential accidents i
involving spent fuel stored in the spent fuel pool, three types of hypothetical accidents were considered: a fuel handling accident, a non-mechanistic heavy load drop, and the criticality potential of a seismically or otherwise load-:
1 induced rearrangement of stored spent fuel assemblies from the existing assembly storage configurations.
Additional hypothetical' accident scenarios considered were:
a non-mechanistic expulsion of all pool water and radionuclide contami-nants of the pool water to the atmosphere, a spent fuel pool rupture, and an-uncontrolled release of all contents of the liquid radwaste tanks to the 4
i discharge canal. These are discussed below.
l 10.1 Fuel Handlina Accident i
The offsite radiological consequences of the drop of a spent fuel assembly onto-the stored spent fuel consist almost entirely of the whole body dose due to the release of the Kr-85 gap. activity contents of two stored assemblies.
This~1s due to the fact that all stored assemblies have a decay time of at least 10 years. The principal thyroid dose contributor, I-131, with an 8.05 day-half-life, has decayed to negligible concentrations -(as are other iodine radio-4 nuclides). A postulated release of the long-lived radionuclide Kr-85, with a e
10.8 year half-life, produces a (0-to-2-hour) offsite whole body dose at the ex-clusion area boundary of_0.1 mrem. This estimate assumes damage to all of'the pins in each of the two assemblies (a conservative assumption, taking into i
account fuel assembly geometry and type).
It also assumes an exclusion-area boundary, one half percentile atmospheric diffusion and transport relative con-centration (X/Q) of 5.2 x 10 3 sec/m. The projected dose from a postulated 3
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fuel handling accident is a small fraction of the 10 CFR Part 100 guideline values of 25 rem to the whole body and 300 rem to the thyroid.
10.2 Non-Mechanistic Heavy Load Drop / Site-Related Hazards The staff determined the (0-to-2-hour) offsite radiological consequences of a non-mechanistic heavy load drop in the spent fuel pool. The staff assumed damage to all of the pins in each of the 390 spent fuel assemblies and'a mini-mum 8 year cooldown time although actual cooldown is over 10 years. The con-sequences were estimated to be 20 mrem whole body dose using the same atmos-pheric diffusion and transport relative concentration as was used in Section 10.1 above. Again, the thyroid dose is estimated to be negligible (less than 0.1 mrem) because I-131 has decayed to essentially zero. These consequences are also very small fractions of and, therefore, are well within the guideline values of 10 CFR Part 100.
The aforementioned non-mechanistic heavy load drop analysis bounds site-related hazards, such as the potential effects of onsite flammable liquids.
For example, the onsite storage of liquid propane may represent a fire or an explosion hazard.
However, its ignition or detonation would not present a significant threat to the integrity of the spent fuel pool.
The damage poten-tial would be primarily in terms of the impact of heavy objects (e.g., nearby equipment or structural debris) which may fall into the spent fuel pool. The aforementioned offsite radiological consequences with respect to the non-mechanistic heavy load drop bound the potential consequences of this type of hazard. Hence, the presence of onsite combustible fuels does not pose a threat of significant offsite radiological consequences with respect to radionuclide releases from stored spent fuel in the spent fuel pool.
10.3 Criticality Potential of Rearranged Stored Spent Fuel Due to Seismic or Other Mechanical Loads The licensee, in its submittal of July 30, 1985, has provided a very thorough analysis of the criticality features of the stored spent fuel configuration.
Both the CASM0-2E computer code (Shiffer, July 85), used by PG&E, and the MERIT computer code (Shiffer, July 85), used by the General Electric Company (GE),
have been previously extensively employed for criticality analyses.
PG&E has provided data to validate its use of the UASM0-2E code.
Likewise, GE has provided data (in other applications) to validate the use of the MERIT code.
The results of the analysis with respect to the effect of varying the internal pitch of an assembly and the distance between stored spent fuel cans is consis-tent with what would be expected for such calculations. The licensee has analyzed the stored spent fuel reactivity for the most reactive combination of the spacing parameters and shows that the calculated values of X reactivityrelatedeffectiveneutronmultiplicationfactor, meet *be,the (maximum) limiting criterion of 0.95 with a margin greater than 0.05.
These calculations make the tacit assumption that any distortions of the racks would leave the basic geometry unaltered, i.e., the fuel rods would remain in 4
a parallel array and be surrounded by the boral plates. This assumption may not be valid under all credible array-altering physical mechanisms.
- However, the following statements can be made about the likely effects of calculational assumptions and possible distortion of a spent fuel assembly geometry:
Humboldt Bay 3 SER 10-2
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The _ assumption of fresh fuel with no credit for the presence of gadolinium,
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a burnable poison, is conservative.
Even-as small an amount of burnup as 1320 mwd / tonne wil1~ reduce the reactivity somewhat.
2.~
.The assumption of infinite length of the assemblies is conservative.
Use
- of the_ correct length would reduce K,ff. by 0.01.
3.
It is very unlikely that any' credible rearrangement of the stored spent' fuel by crushing under seismic or other loads. could-increase the reactiv-l
.ity of the system by.enough:to make it critical;=the licensee's analysis (Shiffer, July _1985) assumed no radial or axial. neutron leakage' for ex-ample,-and, therefore, crushing the assemblies into a pancake geometric
. configuration (with rods still vertical) would reduce the reactivity.
-Likewise, a local pile of fuel pellets (low-enrichment) would very likely-be undermoderated and subcritical.
The staff concludes, therefore, that there is a negligibly'small likelihood that there is any credible means of producing criticality in the stored spent fuel array.
Negligibly small means in this context that the probability of occurrence is so small that the consequences of such an event do not need to be evaluated.
10.4-Non-Mechanistic Expulsion of Pool Water and Radionuclide Contaminants to the Atmosphere 5
In the event of a large seismic event near the site, it is conceivable that some of the spent fuel pool water containing radionuclide contaminants-(chiefly-cobalt, cesium, and strontium) could slosh or splash (due to falling debris)-
through newly-created building fissures or openings.
In order to bound the potential offsite doses due to such a hypothetical occurrence, the staff as-sumed that all radionuclide contaminants in the pool water inventory are re--
i leased instantaneously and directly to the atmosphere.
The integrated-source term assumed for the dose assessment was 9.2 x 10 3 Ci.
of Co-60,1.7 Ci of Cs-137, and 2 x 10 3 Ci of Sr-90. Of-these quantities, one percent was assumed to be inhalable.
No' credit was taken for washout.
Using the same-X/Q value as in Section 10.1.above and the methods of Regula-tory Guide 1.109, the following offsite 50 year inhalation-initiated dose ~
commitments were calculated:
1.2 x 10 1 area to the lung,:2.4 mreu to the liver, and 4.3'x 10 1 mrem to the bone (immersion doses are negligible, in this scenario, compared to inhalation-initiated doses). ' These-doses, which
- i were calculated for the nearest off-site location,' are all very small fractions of the 10 CFR Part 20 dose guideline levels and are acceptable.-
A0.5 Spent Fuel Pool Rupture The consequences of a rupture in the spent fuel pool were analyzed'by the licensee and the staff.
In the analyses the released effluent was assumed to enter the' tidal affected water table aquifer and flow down gradient toward Humboldt Bay.-
The rainy season groundwater level at the spent fuel pool is +9 feet MLLW and the mean tide level is +3.3 feet MLLW.
From estimated values of Hydraulic Con-ductivity of 10,400 ft/ year and effective porosity of.25, a groundwater Humboldt Bay 3 SER 10-3
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velocity-of 564 ft/ year was determined.
Based on the-velocity and a distance.
to Humboldt Bay from.the spent fuel pool of 420 ft, a travel time of about 9 months for the effluent to enter Humboldt Bay was estimated.
The geochemical properties of the site further retard the movements of. radionuclides such as cesium, strontium, and cobalt. To determine the amount of retardation, the licensee estimated distribution coefficients of 1.5 ml/g for strontium and co-balt and 20 ml/g for cesium.
The staff considers these estimates to be reason-able and conservative for the site.
For the release scenario, the licensee assumed that only that effluent in the pool-between the top of the pool and the mean tide level of +3.3 feet MLLW would flow out. Although the staff does not consider the licensee's assumption con-servative for all conceivable release scenarios, the licensee's estimates of amounts released were used by the staff for reasonable dose calculation purposes.
A simple analytical model of contaminant flux through a vertical plane was used to estimate the amounts of Cs-137, Cs-134, Sr-90 and Co-60 entering Humboldt Bay.
From the flux calculation and the licensee release estimates, the staff deter-mined Cs-137 to be the primary contributor to dose with about 3.2 x 10 2 Curies entering Humboldt Bay.
Sr-90 and Co-60 were lesser contributors with 5.2 x 10 4 Curies of Sr-90 and 8.7 x 10 4 Curies of Co-60 entering Humboldt Bay.
For the purposes of the dose calculation of the radionuclides were assumed to remain in Humboldt Bay for one year. This is exceedingly conservative as 44% of the Bay water is flushed into the ocean with each tide cycle.
Based on human food con-sumption from the commercial fish catch data, it was determined that a rupture of the spent fuel pool would result in a total population dose of 0.13 person-rem (Shiffer, February 1985, Regulatory Guide 1.109, October 1977), implying i
an average individual dose commitment less than that of background radiation.
Doses due to water recreational activities would be nenligible compared with those due to seafood consumption. Additionally, there would be no releases of radioactivity due to heatup of the spent fuel since the decay heat generation-rate is less than 100W per fuel assembly. This low heat generation rate would allow the fuel to cool in air by convection currents (Shiffer, February 28, 1985, Appendix B).
If the entire inventory of radionuclides in the spent fuel pool water were assumed to be released, the resulting population dose would still be less than 1 person-rem.
10.6 Uncontrolled Release of Radwaste Tank Contents The licensee presented an analysis of an uncontrolled release from the two con-centrated waste storage tanks located in the Radwaste Treatment Building (Figure 2.1) as a worst case scenario for accidents of this kinti. The licensee assumed that the entire volume of 10,000 gallons of the two tanks flowed directly into the discharge canal. The licensee then calculated the concentra-tions in the canal for Cs-137, Cs-134, Co-60 and Sr-90.
In all cases the li-censee determined that the concentrations in the discharge canal were more than an order of magnitude less then the 10 CFR 20 Appendix B Table II limits. The staff agrees with the licensee's determination.
The staff also made an independent analysis of the tank spill for the purpose
^
of estimating population dose.
The staff assumed that the entire contents of the tanks entered Humboldt Bay and remained there for one year.
This is also Humboldt Bay 3 SER 10-4 I
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o-very conservative assumption because the tidal exchange with the Bay is about:
44 percent per tidal cycle.
The buildup of the various radionuclidestin both-finfish and shellfish was estimated and the commercial fish catch data for Humboldt Bay and Northern California was used to-estimate ~the amount of fish consumed. On the basis of these calculations, using the methods of Regulatory
-Guide 1.109, the~ staff estimated that the annual population _ integrated total body dose resulting'from a tank spill into the discharge canal will be less than 0.1 person-res (Regulatory Guide 1.109, October 1977, Schuyler 1984).-
This means that an average individual consuming Humboldt Bay-harvested finfish/
shellfish following loss of the two ra waste storage. tanks contents to the= bay would receive, from this food source, much less than the average annual back-ground radiation dose received by individuals in the United States. Again,-
doses due to water recreational activities would be negligible compared with j
those due to seafood consumption.
10.7 Impact of Tsunami Floodina As stated in Section 3.2.6, the one flooding event that could seriously impact the site is a tsunami. The likely effect of such an event on plant structures might be the release of the radwaste tank radionuclide contents to the Bay in the backwash of the tsunami and some damage to the reactor b'uilding.
In both cases offsite radiological consequences of these hypothetical events are bounded by those discussed in Sections 10.6 and 10.2, respectively.'
10.8 Accident Analysis Conclusions The staff concludes that a fuel handling accident resulting in damage to two spent fuel assemblies would result in atmospheric radionuclide releases which would result in offsite radiological consequences that= are a small fraction of '
the guideline values of 10 CFR Part 100.
The staff similarly concludes that a non-mechanistic heavy load drop or equiva-lent site-related hazard accident initiator, either phenomenon resulting in damage to all the stored spent fuel assemblies in the pool, would result in atmospheric radionuclide releases leading to offsite radiological consequences l
which are also a small fraction of the guideline values of 10 CFR Part 100.
It is also concluded that there is a negligibly small likelihood of an acciden-tal criticality generated among the spent fuel assemblies stored in the pool due to seismic loads or other mechanical loads.
The staff has determined that 50 year lung, liver, and bone dose commitments due to an upper-bounding instantaneous expulsion to the atmosphere of the en-tire water /radionuclide content of the spent fuel pool are very small fractions l
of the 10 CFR Part 20 guideline values.
l The staff has considered a spent fuel pool rupture and rupture of t'he liquid radwaste tanks.
In either case'the total body dose to an average individual l
via the seafood chain would be less than natural background levels.
Doses due l
to water recreational activities in Humboldt Bay would be negligible in comparison.
l The staff has determined that offsite radiological consequences due to a tsu-nami are bounded by those of the liquid radwaste tank rupture and the non-i L.
Humboldt Bay 3 SER 10-5
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~11 EMERGENCY PLANNING 11;l Introduction s
.On April-4, 1985, the-licensee submitted the proposed Humboldt Bay Power-Plant
-(H8PP), Unit 3 Emergency Plan, Revision 0, SAFSTOR, describing the emergency.
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1 facilities, organizational. control of emergencies, and corrective actions that will be carried out in the event.of an-emergency at Humboldt Bay Unit 3 during i
the SAFSTOR' period.
Supplemental information and. commitments were provided in
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.PG&E letters to the NRC dated June -12,.1986 and January 20, 1987.
I The NRC staff has utilized the same acceptance criteria for the review of the SAFSTOR Dnergency Plan as used to evaluate' the adequacy of onsite emergency plans for nuclear power reactors, 'with modifications. in the application of: the i
criteria in view of the operational. status and inherent low risk of Humboldt Bay Unit'3 in the SAFSTOR mode. The acceptance criteria include the planning i
- standards of 10 CFR 50.47(b), the requirementsLof Appendix E =to' 10 CFR 50, and 1
.the guidance criteria of NUREG-0654/ FEMA-REP-1,-Revision 1, " Criteria for Preparation and Evaluation of Radiological Emergency Response' Plans and Pre-l paredness in Support of Nuclear Power Plants," dated November. '1980.
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The potential for emergency events to occur during the SAFSTOR period and their
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possible consequences are discussed in the Emergency Plan. All irradiated fuel-has been removed from the reactor vessel and is being stored in the spent fuel j
pool. The radioactive' source terms for an accidental' release have been greatly
~
1-reduced by radioactive decay. Additionally, the remaining decay heat contained in the irradiated fuel is low enough to preclude fuel cladding damage should a loss of water inventory in the spent fuel pool-occur. Based on an analysis-of j
possible events at Humboldt Bay Unit 3, the, licensee states in the emergency i
plan that there are no postulated accidents which could result in the release of radioactive materials to the environment in quantities which would require -
protective actions for the public.
i l.
The NRC staff has evaluated the offsite radiological consequences of potential
~
accidents involving'the fuel stored in the spent fuel pool including a fuel handling accident, a non-mechanistic heavy load drop, and a seismically-or otherwise-induced rearrangement of the stored spent = fuel assemblies. Other r
hypothetical accident scenarios considered by the staff were a non-mechanistic expulsion of all pool water to the atmosphere, a spent fuel" pool-rupture,:and an uncontrolled release'of all contents of the liquid radwaste tanks to the discharge canal. The results.of the staff's review are presented in the FES (NUREG-1166) and Section 10 of this SER. The staff concluded that-i t
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-the postulated accidents result in' atmospheric radionuclide releases that are.
well below Protective Action Guide
- levels. -In addition, the-staff concluded that there is a negligibly small likelihood of a criticality accident among the spent fuel assemblies stored in the pool and that doses resulting from liquid releases would be very low.
Section 11.2 of this report lists each planning standard of 10 CFR 50.47(b) followed by an evaluation of the applicable portions of the Emergency Plan that relate principally to that particular standard. The staff's conclusions
.are presented in Section 11.3.
11.2 Evaluation of the Emergency Plan 11.2.1 Emergency Classification System Incidents at nuclear power plants are categorized into one of four emergency classes according to a graduated level of severity; i.e., Notification of Unusual Event (NUE), Alert, Site Area Emergency, and General Emergency. The licensee has evaluated the potential consequences of a spectrum of postulated accidents and states that there are no postulated accidents for Humboldt Bay Unit 3 during SAFSTOR which could result in an emergency classification more severe than an NUE. A listing of initiating conditions and emergency action levels associated with possible events at Humboldt Bay Unit 3 which would result in the declaration of an NUE is given in Table 11.1 of this report (from Table 3.1-1 of the Emergency Plan).
11.2.2 Emergency Facilities and Equipment The SAFSTOR Emergency Plan provides for facilities which are intended to be used as response centers in the event of an emergency situation. These in-clude the control room, a conference room in the administrative building which is the onsite alternate location in the event the control room is inaccessible, and the Eureka Service Center located approximately 5 miles north of the plant which is an alternate offsite emergency location. The communications capabil-ities for these facilities include company direct dial and Pacific Bell tele-phones as well as access to the company VHF radio system.
Assessment systems and equipment include an area radiation monitoring system, a process radiological monitoring system, a radiological counting room which is used for radiochemical determinations, portable survey instruments, and a radiological emergency kit located in the conference room. Protective cloth-ing, respiratory protection equipment, air samplers, and other standard radio-logical equipment and supplies are available for emergency use. Provisions have been made to periodically check the equipment and to maintain adequate 1
supplies.
- The Protective Action Guide (PAG) is the projected dose to individuals in the population which warrants taking protective action.
(U.S. Environmental Pro-tection Agency Manual of PAGs and Protective Actions for Nuclear Incidents, Revised June 1980.)
0:
Humboldt Bay 3 SER 11-2
e TABLE 11.1 Emergency Action Levels Notification of Unusual Event Classification.
l'.
Instantaneous radiological effluent technical specification limits exceeded.
2.
Any accident involving spent fuel-(fuel handing accident, heavy load
~
drop into spent fuel pool, or criticality).
3.
Radiation levels or airborne contamination which. indicate a severe degradation in the control of radioactive materials (e.g., increase by a factor of 1,000 in direct radiation readings within facility).
4.
Sudden loss of or serious degradation to any of the following:
a.
Fire-fighting capability.
b.
Radwaste storage and/or treatment system integrity.
5.
Any of the following criteria involving fires:
a.
Any fire which involves radioactive materials, lasting > 30 minutes, b.
Any fire in which offsite assistance is requested.
6.
Security threat requiring offsite law enforcement assistance.
7.
Near or onsite toxic or flammable gas release.
8.
Transportation of contaminated injured individual from onsite to offsite hospital.
9.
Radiation exposure exceeding the limits specified in 10 CFR'20 for immediate notifications.
8 5
1 Humboldt Bay 3 SER 11-3
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11.2.3 Emergency Communications HBPP communications capabilities include a Pacific Bell telephone ~ system,'a' company direct dial Ltelephone: system, a VHF radio system and an inter-communi-cation system. The company telephone system is designed to remain operable in
~
an. emergency situation with power provided~by a separate, dedicated DC system.
The company-system _ has a code call feature for communicating with key members' of the plant staff. The VHF radio : system can be utilized in-an' emergency to -
, establish communications' with the Humboldt County LSheriff's '0peration Center.
11.2.4 Medical and Public Health Support'-
The SAFSTOR Emergency Plan states that General-Hospital and St.. Joseph 'Hospf--
tal,.both' located in Eureka, have agreed to-acceptaand-treat-any person who-
. is injured and contaminated. -In the event these hospitals are unable to pro-vide treatment, the patient will be airlifted to St.. Francis Hospital-in San.
Francisco. The company also retains a' panel of physicians who can be' called upon in the event of a medical emergency at Humboldt Bay Unit 3.
The licen--
see has-made arrangements with a local ambulance company in Eureka _to provide
-ambulance service for injured company employees including'those-that might be contaminated.
Standard first-aid kits, blankets and basket stretchers are placed at various-locations throughout the plant. All plant personnel-receive.first-aid training on an annual basis.
11.2.5 Assignment of Responsibility (Organizational Control)
The SAFSTOR Emergency Plan describes the organizations that are intended to be '
~
part of the overall response effort in the event of an emergency at Humboldt Bay Unit 3.
In addition-to the normal plant operations " staff, these organiza-tions_ include the licensee's corporate headquarters' staff, 1ocal and regional service support groups which provide police, medical, hospital', ambulance and fire-fighting assistance, industrial support organizations,'~and Federal', state and-local governmental agencies.
In the event of an emergency, the normal onshift' operations ' personnel are responsible for initial evaluation of the incident, performing any immediate :
operations.which are necessary to mitigate the consequences of the incident, and activating the emergency plan. The senior member of'the' operations staff (normally the Shift Foreman) assumes the position of Emergency Coordinator (EC)-
until relieved by a senior member of the plant" staff.. Thus there_will be a-qualified EC on duty at all times. The licensee will maintain a minimum five-
. person shift organization during the safe storage period of Unit 3.
The group with overall responsibili.ty-for coordinating additional company resources is the Nuclear Operations Support (NOS) Department located in the PG&E Corporate Of fices'.
The Humboldt County Sheriff's Department is the ' local' alerting agency which will be notified by the EC in the event of any emergency at Humboldt Bay Unit 3.
The Sheriff's Operations Center is manned on a 24-hour per day basis.-
Upon notification from the EC, the Sheriff's-Department would, if appropriate, notify the County Office of Emergency Services (OES), the California Highway -
Patrol, the' City of Eureka Police Department, and Fire District'No. 1.
The Humboldt Bay 3 SER 11-4
i County OES is responsible for coordinating and supervising the implementation of the Humboldt County Emergency Plan.
In a letter dated January 20, 1987, the licensee informed the NRC that existing letters of agreement addressing medical and firefighting services in support of Humboldt Bay, Unit 3 are in the process of being renewed by PG&E with the appropriate organizations. These organizations, located in Eureka, California, are Humboldt No.1 Fire Protection District, St. Joseph's Hospital, General Hospital, and City Ambulance Service.
The licensee stated that the renewal of agreements is expected to be completed before June 1, 1987. These renewed agreements will be appended to the Emergency Plan. A letter of agreement is I
also in effect with St. Francis Hospital in San Francisco to provide medical I
services. The letters of agreement will be reviewed and certified on an annual basis.
1 11.2.6 Onsite Emergency Organization The onsite emergency organization of plant staff personnel is described in the i
SAFSTOR Emergency Plan. The normal shift complement consists of a minimum 1
five person organization. During spent fuel handling operations, at least one l
additional qualified person will be onsite.
In the event of an emergency, the senior member of the normal operations staff (normally the Shif t Foreman) i assumes the position of EC until relieved by a senior member of the plant staff. The basic responsibilities and authorities for each position in the emergency organization including the EC are specified in the plan. The respon-sibilities of the EC include the responsibility to ensure that emergency noti-fications and any protective action recommendations are provided to Humboldt County. The EC is also responsible for notifying or directing the notification of the State of California and the NRC.
The normal operations shift staff is augmented in an emergency by other members of the plant staff organization. Appropriate individuals from the corporate staff would be called upon, as necessary, to assist in an emergency.
The com-pany has an extensive staff of technical specialists who are familiar with the Humboldt Bay Unit 3 and have expertise in reactor operations, radiological assessment, meteorology and other support functions. The Nuclear Operations Support (NOS) Department at corporate headquarters maintains liaison with governmental agencies and other organizations not located in the HBPP locality and provides technical assistance to the onsite staff.
11.2.7 Emergency Response Support and Resources Arrangements have been made by the licensee to utilize offsite organizations to assist the HBPP normal plant operations staff in emergency mitigation and recovery efforts. Agreements with local service support organizations provide for immediate 24-hour per day, on-call response. Other organizations having an emergency response role include Federal, state and local governmental agencies.
The lead local agencies for offsite support are the Hu:boldt County Sheriff's Department and the County Office of Emergency Services (OES). Upon notifica-tion of an emergency at Humboldt Bay Unit 3 by the Sheriff's Department, the County OES would, if appropriate, alert the County Board of Supervisors, the County Administrative Officer, and all County, City of Eureka and private agencies involved in the implementation of the Humboldt County Emergency Plan.
Humboldt Bay 3 SER 11-5
The Emergency Operations Center in the County Courthouse would become the coordinating center for the County plan.
11.2.8 Notification Methods and P*rocedures The licensee has established an emergency classification scheme which results in the declaration of an emergency, that is, a Notification of Unusual Event, whenever certain specified emergency action levels are exceeded. The senior member of the normal operations staff (i.e., the Shift Foreman) assumes the position of Emergency Coordinator (EC) and is responsible for activating the Emergency Plan and ensuring that the local alerting agency, the Humboldt County Sheriff's Department, is notified.
In a change to the Emergency Plan submitted on June 12, 1986, the licensee committed to notify Humboldt County as soon as practical or within one hour of the declaration of an emergency at Humboldt Bay Unit 3.
This time is measured from the time at which the Shift Foreman recognizes that events have occurred which make the declaration of an emergency appropriate.
Several warning signals and alarms are available to alert onsite personnel of an emergency. Call-out of personnel to augment the shift staff is accom-plished by telephone. An on-call system is utilized to ensure that a senior staff member is available to relieve the Shif t Foreman and assume the posi-tion of EC. The on-call individual carries a " beeper" that can be used for emergency notifications. The corporate emergency organization is activated by the EC by notifying the designated on-call members of the Nuclear Opera-tions Support Department. Corporate assistance can also be obtained by call-ing the Energy Dispatch Control Center in San Francisco which is staffed on a 24-hour per day basis.
Initial and follow-up emergency messages are provided to the Sheriff's Depart-ment. Provisions are included for message authentication. The Sheriff's Department in turn notifies other State, County and City of Eureka offices including the County Office of Emergency Services (OES). The County OES is responsible for activating the County Emergency Plan and alerting the involved agencies and organizations.
11.2.9 Public Education and Information PG&E will mail an information brochure containing plant and emergency planning information to the public annually. PG&E has a public information department in its corporate organization which would provide information to the media and the public in the event of a declaration of an emergency at Humboldt Bay Unit 3.
Information on the occurrence of an emergency for the public would also be provided through the activation of the Humboldt County Emergency Plan.
Postulated accidents at the plant are not expected to result in any offsite releases of radioactive materials at levels which would require the implemen-tation of offsite protective actions such as evacuation or shelter for the public.
11.2.10 Accident Assessment The systems and equipment for assessing and monitoring the actual or potential consequences of a radiological emergency condition are described in the Plan.
Humboldt Bay 3 SER 11-6
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l An area radiation monitoring system (ARMS) consisting of a system of perma-nently installed radiation monitoring detectors is-located throughout the plant. ARMS measures the ambient radiation level in each monitored area and is used for' personnel radiation protection purposes and to alert plant staff to the release of radioactive material within a plant structure, f
A process radiological monitoring system continuously monitors the plant li-quid and gaseous plant process streams for radioactivity.
Information from t
l this system provides an indication of equipment performance as well as radie-I active release data. Portable survey and dose rate instruments are available for routine radiological monitoring and for use in emergencies. The plant has a radiological counting room with equipment for radiochemical sample analysis.
f l
Real-time radiological release information, provided by the stack effluent f
monitoring system, along with estimated noble gas inventories and conservative atmospheric dispersic.n factors for the nearest site boundary location, are used to estimate offsite doses. The Emergency Evaluations Coordinator is respon-sible for assessing the actual or potential radiological consequences of an accident. The Emergency Evaluations Coordinator position is initially filled by the on-shift Senior Control Operator.
The Radiological Emergency Evalua-tor, who is initially the on-shif t Assistant Control Operator, is responsible for coordinating onsite and offsite radiological surveys. Plant personnel have been designated to relieve the on-shift staff of these emergency organi-zation positions for long-term response. The plant emergency organiza'. ion also includes emergency radiological teams for performing radiation surveys and other radiation protection functions.
Technical assistance for the plant staff is available through the corporate headquarters support' organization which includes specialists in dose assessment and meteorology.
11.2.11 Protective Response The protective response actions for onsite personnel including plant staff, visitors and contractors are described in the plan. Onsite personnel are alerted that an emergency condition exists by the sounding of the emergency signal over the plant roof top siren, the only plant signal that utilizes a siren. Visitors and other non-company personnel are briefed on the meaning of plant emergency signals and their response upon entry to the site. Other alert signals for onsite personnel are provided by the telephone code call system and the refueling building evacuation alarm which is initiated by the criticality monitors in the spent fuel pool area.
The licensee has several methods for performing a rapid assessment of plant accountability including an identification badge program and controlled area logs.
If the site emergency signal is sounded, each person is instructed to go to a specific preselected in plant assembly area. A supervisor is assigned to each assembly area and is responsible for accounting for the assembled personnel.
Nonessential onsite personnel may be evacuated in an emergency at the decision of the Site Emergency Coordinator.
If it is necessary to evacuate the site, all nonessential personnel would leave by automobile, travel in convoy, and
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assemble at the PG&E Myrtle Avenue Service Center.
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1 Humboldt Bay 3 SER 11-7 l
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Predetermined protective measures such as evacuation or shelter are not expec-ted to be required for the general public. Accident analyses for a spectrum of postulated accidents by the licensee, supported by NRC staff evaluation, indicate that offsite doses for any credible accident would be well below PAG levels. Any necessary instructions for the public on what actions to take in the event of an emergency at Humboldt Bay Unit 3 would be provided at the time of the incident by offsite authorities based on information from plant and corporate personnel.
11.2.12 Radiological Exposure Control Management of the exposure control program for onsite emergency workers during accident conditions is assigned to the Emergency Evaluations Coordinator, with assistance from the Radiological Emergency Evaluator (REE). Monitoring teams would be established under the direction of the REE. The teams are responsible for determining radiation levels around the plant and for monitoring individ-uals. The teams have various portable radiological instruments available for both emergency and routine use. There are also permanently mounted area radi-ation monitors which will sound an alarm at preset levels. Respiratory protec-tion equipment is available if entry is required into areas where the maximum permissible concentrations are exceeded.
Onsite emergency workers wear personal dosimeters to monitor their exposure.
The exposure guidelines used are consistent with the Environmental Protection Agency emergency worker and lifesaving activity protective action guides (PAGs). The Emergency Coordinator may authorize volunteers to receive higher exposures according to these PAGs for extraordinary lifesaving missions.
Otherwise, the normal quarterly and annual exposure limits will be observed.
11.2.13 Recovery and Reentry Planning The SAFSTOR Emergency Plan describes the general actions to be followed by the licensee for recovery and reentry operations. Guidelines have been developed for the protection of workers entering the affected areas of the plant. The Emergency Coordinator is responsible for approving all reentries into evacuated plant areas.
11.2.14 Exercises and Drills A periodic drill program covering various aspects of the Emergency Plan is summarized in the plan. Specific drills to be performed include the following:
One annual announced emergency drill of a simulated emergency affecting the entire site.
One annual unannounced drill affecting the entire site.
Monthly fire drills.
In addition, the radio communications network is checked on a weekly basis.
The HBPP Plant Manager is responsible for the conduct of the emergency plan drills. The planning and scheduling of the drills is the responsibility of the Senior Chemistry and Radiation Protection Engineer along with other key supervisory personnel.
Following a drill, observers and principal partici-pants meet with the Plant Onsite Review Committee to critique the drill.
Humboldt Bay 3 SER 11-8
Drill audits are performed by the corporate Nucleari0perationsISupport Department.
11.2.15 Emergency Response Trafning Emergency-response training is discussed in Section 6.2.1.5.
.11.2.16l' Responsibility for the Planning Effort: Development, Periodic Re-d view and Distribution of Emergency Plans The Plant Manager has the overall responsibility for emergency planning at the Humboldt Bay Power Plant. The individual responsible for the development,-
updating, coordination and technical direction of the Emergency Plan is'the
- Power Plant Engineer.
.The SAFSTOR Emergency Plan is-reviewed an'd updated at least once every two
' years. The Plant Staff Review Committee (PSRC) maintains documentation sub-stantiating the review.and update. Company corporate emergency planning personnel also periodically review the plan. Contact and notification lists
-are updated on a quarterly basis to ensure correct listing of; telephone _num-bers and responsible individuals.
Local participating response organizations with which a letter of agreement has been signed are contacted on an annual-basis to certify the agreement.
Revisions to the Plan are controlled and distributed in accordance with plant document control procedures. This process requires review by the PSRC and' approval of the Plant Manager. Changes and revisions to the Plan are issued to holders of controlled copies through the document control agreement.
11.3 Emergency Planning Summary On the basis of a review of the Humboldt Bay Power Plant Emergency Plan Revi-sion 0 (SAFSTOR) against the acceptance' criteria included in 10 CFR 50.47(b),
Appendix E to 10 CFR 50 and NUREG-0654/ FEMA-REP-1, and considering the opera-tional status and low likelihood of any credible accident resulting in-radio-logical releases requiring offsite protective measures as supported by licensee and staff accident analyses, the staff concludes that (1) the Emergency Plan, including licensee commitments, provides an adequate basis for an accept-able state of emergency preparedness, and (2) the Emergency-Plan, in conjunc-tion with arrangements made with offsite response agencies, provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at Humboldt Bay Unit 3 during SAFSTOR.
Humboldt Bay 3 SER 11-9
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- 12. CONCLUSIONS On the basis 'of our evaluation of the licensee's application to amend License No. OPR-7.to: -(1)-delete certain license conditions related to seismic modifi-cations required before the NRC would authorize a return to power operation;.
(2) revise the Technical Specifications to reflect the possess-but-not-operate status;.(3)' decommission Humboldt Bay Unit 3 in accorcance with the plan included with the submittal; and (4) extend License No. OPR-7:for.15 additional years, we
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have' concluded that: (1).there.is a reasonable assurance that the health and -
safety of the public will not be endangered by maintenance of the facility in
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-the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations, and the issuance of this amendment will not be inimical to tiie common defense and security or to the health and. safety of the public.
Humboldt Bay 3 SER 12-1 a
e 13-CONTRIBUTORS This Safety Evaluation Report is a product of the NRC staff. The principal contributors to this report are:
Staff Title Organization Peter Erickson Project Manager Standardization & Special Projects Directorate Michael Lamastra Health Physicist Plant Systems Branch Charles Nichols Senior Nuclear Engineer Plant, Electrical, Instrumentation & Control Systems Branch Jerry Swift Reliability & Risk Analyst
-Reliability & Risk Assessment Branch Rex Wescott Hydraulic Engineer Plant Systems Branch Frank Witt Chemical Engineer Plant Systems Branch Millard Wohl Reactor Engineer Technical Specification Coordination Branch Walter Brooks Nuclear Engineer Reactor Systems Branch Robert Wood State Relations Analyst Office of State Programs Mary L. Roe Training Assessment Maintenance and Training Specialist Branch William Belke Quality Assurance Engineer Quality Assurance Branch Ina Alterman Geologist Mechanical / Structural Engineering Branch Falk Kantor Section Chief Emergency Preparedness Branch Humboldt Bay 3 SER 13-1
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s.
14 REFERENCES International Commission on Radiological Protection (CRP), " Recommendations of-the International Commission on Radiological Protection," ICRP Publication 26, January 1972.
United Nations Scientific Committee on tne Effects of Atomic Radiation (UNSCEAR),.
" Ionizing Radiation:
Sources and Biological Effects," 1982.
National Academy of Sciences, Advisory Committee on the Biological Effects of Ionizing Radiation, "The Effects on Populations of Exposure to Low Levels of Ionizing Radiation" (BEIR I), 1972.
--, "The Effects on Populations of Exposure to Low Levels of Ionizing Radiation" (BEIR III), 1980.
National Council on Radiation Protection and Measurements (NCRP), " Review of the Current State of Radiation Protection Philosophy," NCRP Report No. 43, January 1975.
Nuclear Waste Policy Act of 1982 (Public Law 97 '425, January 7, 1983).
Pacific Gas and Electric Company (PG&E), " Final Hazards Summary Report -
Humboldt Bay Nuclear Power Plant Unit No.
3," September 1, 1961.
Schuyler, J. O., PG&E, letter to H. R. Denton, NRC, HBL-84-027, July 30,1984.
Shiffer, J. D., PG&E, letter to J. A. Zwolinski, NRC, " Responses to NRC staff questions of January 23, 1985," February 28, 1985.
--, letter to J. A. Zwolinski, NRC, " Responses to NRC staff questions of January 23, 1985 and February 14, 1985," April 3, 1965.
--, letter to J. A. Zwolinski, NRC, " Flood Hydrology," July 11, 1985.
--, letter to J. A. Zwolinski, NRC, "Humboldt Bay Power Plant Unit 3 Criti-cality Analysis for SAFSTOR Decommissioning," July 30, 1985.
--, letter to J. A. Zwolinski, NRC, "Humboldt SAFSTOR Decommissioning-Document Transmittal," October 7, 1985.
--, letter to H. N. Berkow, NRC, " Custodial SAFSTOR Facility Quality Assurance Plan, Revision 1," December 13, 1985.
--, letter to H. N. Berkow, NRC, " Proposed SAFSTOR Technical Specifications,"-
March 13, 1986.
--, letter to H. N. Berkow, NRC, " Custodial SAFSTOR Facility Quality Assurance Plan, Revision 1," March 11, 1986.
Humboldt Bay 3 SER 14-1 1
s
--, letter to H. N. Berkow, NRC, " Change to Proposed SAFSTOR Technical Speci-fications," May 23, 1986.
--, letter to'H. N. Berkow, NRC, "PG&E. Responses to Public Comments on DES for Decommissioning Humboldt Bay Unit 3," October 20, 1986.
--, letter to NRC Document Control Desk,'" Decommissioning - Additional. Infor-nation," January 20, 1987..~
--, letter to NRC Document Control Desk,'" Spent Fuel Pool Liner Gap Level Exceeded the Control Band," January 22, 1987.
U.S. Nuclear Regulatory Commission, " Order for Modification of License,"
May 26, 1976.
U.S. Nuclear Regulatory Commission, " Order for Modification of License,"
December 30, 1976.
U.S. Nuclear Regulatory Commission, " Amendment of License No. DPR-7 to Possess-But-Not-Operate Status," letter 6505-07-023, July 16, 1985.
--, " Waste Confidence Decision," 49 FR'34658-34688, August 31, 1984.
--, Proposed Rule On Decommissioning Nuclear Facilities, 50 FR 5600, February 11, 1985.
l
--, Regulatory Guide (RG) 1.8, " Personnel Selection and Training,"
Revision 1-R, May 1977.
--, RG 1.109, " Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I,". Revision 1, October 1977.
--, RG 1.144, " Auditing of Quality Assurance Programs for Nuclear Power Plants,"
Revision 0, January 1979.
--, RG 1.146, " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants," Revision 0, August 1980.
--, RG 1.21, " Measuring, Evaluating, and Reporting Radioactivity in Solid Waste and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants," Revision 1 June 1974.
--, RG 1.88, " Collection, Storage and Maintenance of Nuclear Power Plant Quality Assurance Records," Revision 2, October 1976.
--, RG 4.2 " Preparation of Environmental Reports for Nuclear Power Stations,"
Revision 2, July 1976.
--, RG 4.15, " Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment," Revision 1, February 1979.
--, RG 8.29, " Instruction Concerning Risks from Occupational Radiation Exposure," Revision 0, July 1981.
.1 Humboldt Bay 3 SER 14-2 b
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e
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--, RG 8.8, "Information Relevant to Ensuring.that Occupational: Radiation-Expo-sures at Nuclear Power Stations Will Be as Low as.Is Reasonably Achievable,"
Revision 3, June 1978.
't
--, NUREG-0554, " Single Failure Proof Cranes for-Nuclear Power Plants,"
g May 1979.
--, NUREG-0555, " Environmental Standard Review Plans," May 1979.
--, NUREG-0575, " Final Generic Environmental Impact Statement.on Handling and Storage of Spent Light Water Power Reactor Fuel," August 1979.
--,.NUREG-0586, " Draft Generic Environmental Impact Statement on Decommissioning
-of Nuclear Faci 11 ties," January 1981.
N
--, NUREG-0612, " Control of Heavy Loads at Nuclear. Power Plants," July 1980.
--, NUREG-0654/ FEMA-REP-1, " Criteria for Preparation and Evaluation of Radio-logical Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, November 1980.
--, NUREG/CR-0672, " Technology,-Safety and Costs of Decommissioning a Reference Boiling Water Reactor Power System," June 1980.
--, NUREG/CR-0709, " Safety Evaluation Re' port Related to the Removal of Materials License SNM-1265 for the Receipt, Storage, and Transfer of Spent Fuel Pursuant to 10 CFR Part 72, Morris Operation, General Electric Company," July 1981.
NUREG-0766, " Effects of November 8,1980 Earthquake on Humboldt Bay Power Plant Q
and Eureka, California Area," April 1981.
--, NUREG-0800, " Standard Review Plan for the Safety Review of Light-Water-Cooled Reactors,'.' July 1981.
--, NUREG/CR-1106, Brandsma, Pivoky D., and Havang L., " Tsunami Atlas for the Coasts of the United States," Tetra Tech, Inc, October 1979.
--, NUREG-1166, Draft Environmental Statement for. Decommissioning Humboldt Bay:
Power Plant Unit No. 3, April 1986.
Woodward-Clyde Consultants, " Evaluation of the Potential for Resolving the Geologic and Seismic Issues at the Humboldt Bay Power Plant Unit No.
3,"
October 1980.
U.S. Weather Bureau, " Interim Report, Probable Maximum Precipitation in California," Hydrometeorological Report No. 36,. Washington, D.C., October 1966 with revisions, dated October 1969.
Harris, D.
L., " Tides and Tidal Datums in the United States," U.S. Army Corps of Engineers CERC, SR #7, February 1981.
Houston, J. R. and A. W. Garcia, " Type 16 Flood Insurance Study: Tsunami Predictions for the West Coast of the Continental United States, O.S. Army
?
Engineers Waterways Experiment Station, December 1978.'
Humboldt Bay 3 SER
. 14-3
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e Public utilities Commission of the State of California, Decision 85-12-022, December 4,1985, on Application of Pacific Gas and Electric Company for authority to increase its electric rates to reflect retirement and decommis-sioning of Humboldt Bay Power Plant, Unit No. 3.
U.S. Environmental Protection Agency Manual of PAGs and Protective Actions for Nuclear Accidents, Revised June 1980.
1
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Humboldt Bay 3 SER 14-4
a-APPENDIX A' PUBLIC UTILITIES ComISSION STATE OF CALIFORNIA T
HUMBOLDT BAY UNIT 3 OECOMISSIONING FUNDING DECISION NO. 85-12-022 d
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' Appendix A-
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Humboldt' Bay SER 3 A-1 1
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Public Ettlttten Gammission STATE OF CAUFOMNIA
,u Decision 85-12-022 December 4, 1985 l'
ALL PARTIES OF RECORD IN A.83-09-49 TO:
The Administrative Law Judge's proposed decision was signed without change by the Commission and accordingly, a separate document will not be filed and served under AB 2570 in order to save the expense of reproduction.and postage.
Mary Carlos Chief Administrative Law Judge MC: ad 4
4 RECElVED Y295 i
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Decision 85-12-022 December 4,1985-i BEFORE THE PUBLIC UTILITIES COMMISSION.0F THE STATE OF CALIFORNIA.
Application of PACIFIC GAS AND'
)
ELECTRIC COMPANT for authority to
)
increase its electric rates to reflect)
Application 83-09-49 retirement and decommissioning of
) (Filed September 19, 1983)
Humboldt Bay Power Plant, Unit No. 3. )
d
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(For appearances see Decision 85-08-046) 4 PEASE II OPINION I'.
Summary We allow Pacific Gas and Electric Company (PG&E) to recover the cost of decommissioning the prudently constructed plant at Humboldt Bay Power Plant, Unit No. 3 (Unit 3).
The cost of decommissioning Unit 3 currently is. estimated as $58 million.
This estimate includes the cost of decommissioning certain plant facilities which were disallowed as imprudent expenditures in Decisions (D.) 85-08-046 and 85-11-046.
PG&E's shareholders will bear the cost of decommissioning the plant facilities which already have been disallowed for ratemaking purposes.
PG&E's ratepayers will pay the decommissioning cost for the prudently constructed plant.
I The decommissioning fund shall be collected over a four l
year period, coinciding with the four-year amortization period adopted for recovery of Unit 3's retirement expense.
We adopt the Public Staff Division's (PSD's) recommendation that electric rates should be lowered by 83,889,000 to reflect i
reduced operation and maintenance expense for Unit 3 when it enters SAFSTOR on January 1,1986.
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o A.83-09-49 ALJ/md Last, PG&E shall reflect in its tariffs other adjustments due to the sale of unused nuclear fuel or to tax rulings on the decommissioning fund during the four-year accrual period.
II.
The Decommissioning Process Decommissioning is the set of procedures undertaken to The first step in remove a nuclear plant from service.
decommiasioning Unit 3 is placing the plant in SAFSTOR.
SAFSTOR is a process intended to put Unit 3 in a " mothball" SAFSTOR condition with adequate assurance of public safety.
activities include unloading the reactor core and storing the spent nuclear fuel on site, draining and flushing plant systems, decontamination, modification of plant systems to render them nonfunctional for the dormancy period, and implementation of a After the SAFSTOR activities surveillance and maintenanca program.
are concluded, the plant begins a dormancy period of up to 30 years referred to as custodial SAFSTOR.
The next step in decommissioning Unit 3 cannot be undertaken until the Department of Energy (DOE) approves a disposal l
[
Until a DOE approved disposal facility for spent nuclear fuel.
facility is available, Unit 3's spent nuclear fuel must remain on j
The 30-year dormancy period of custodial SAFSTOR is expected site.
j to approximate the amount of time that DOE will need to approve a l
disposal facility.
The decommissioning plan may change over the next 30 PG&E's current plan is to dismantle Unit 3 under the DECON l
l years.
l alternative.DECON is the removal and shipping of all structures, I
systems, and components with radioactive contamination above After the i
unrestricted access levels to approved disposal sites.
Nuclear Regulatory Commission (NRC) confirms that any residual f
radiation is below the unrestricted use level, Unit 3's " possession only" license will be terminated and Unit 3 then will be fully
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decommissioned.
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r A.83-09-49 ALJ/e.i III.
The Cost of-Decommissioning Unit 3-Both PG&E and PSD have based the estimated cost of decommissioning Unit 3 on a study completed by Gibbs and Hill, Inc.
l and Nuclear Energy Services, Inc. in 1982.
The study showed the cost If escalated of decommissioning to be $42 million in 1981 dollars.
to 1986 dollars, the cost increases to $58 million.
IV.
The Collection and Management of the Decommissioning Fund PG&E proposes that the decommissioning fund should be collected over a 15-year accrual period at an annuity rate of $6 32 The estimated revenue requirement, which includes million per year.
PG&E income tax of $6.632 million, amounts to S13 million per year.
suggests that an ongoing review of the revenue requirement for decommissioning could occur in the triennial general rate cases.
PSD agrees with the assumptions used by PG&E to derive a
$13 million annual revenue requirement.
However, PSD asserts that PG&E's electric rates for 1986 should be decreased by $4,693,000-to reflect reduced operating and maintenance expense for Unit 3 and the sale of nuclear fuel.
PSD finds that the current base rate allowance of 34,589,000 for operating and maintaining Unit 3 will be reduced to when Unit 3 enters the 30-year dormancy period for custodial 3700,000 In addition, PSD claims PG&E soon will realize $804,000 SAPSTOR.
from the sale of 44 unused nuclear fuel assemblies.
Recognition of these two events results in PSD's suggested base vate decrease of S4,693,000.
The Redwood Alliance (Alliance) does not dispute the The Alliance does estimated cost of decommissioning Unit 3 i
recommend that the accrual period should be two to four years rather
)
The Alliance also contends that the cost of than 15 years.
decommissioning should be equally shared by ratepayers and i
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r-D' A.83-09-49 ALJ/ad Finally, the Alliance proposes that a cost monitoring shareholders.
system overseen by an Independent Eoard of Consultants should be established to review the decommissioning process.
Y.
Issues PG&E's decommissioning request raises the following issues:
I Whether the cost of decommissioning Unit 3 1.
should be allocated between PG&E's ratepayers and shareholders.
Whether the decommissioning fund should be 2.
collected over a two to four-year period or a 15-year period.
Whether a cost monitoring system and an 3
Independent Board of Consultants should be ordered to tra'ck and manage the decommissioning fund.
4 Whether PG&E's rates should be lowered to reflect a reduction of Unit 3's operation and 4.
maintenance expense-and the sale of unuswd nuclear fuel.
VI.
Discussion Ratepayers are responsible for the cost of decommissioning A.
the prudently constructed plant at Unit 3 The Alliance asserts that PG&E unreasonably and imprudently The Alliance contends r
delayed the accrual of a decommissioning fund.
that a close review of PG&E's actions from 1972 to 1985 reve Eecause of PG&E's conduct, the pattern of errors and omissions.
Alliance believes shareholders should pay as much as one-half of the i
decommissioning cost.
The Alliance points out that PG&E has set aside a mere for decommissioning while the current estimated cost is i
8577,000 The Alliance submits that the large difference between
$58,000,000.
the two figures alone suggests that PG&E was imprudent.
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.v A.83-09-49 ALJ/md The Alliance notes that in.1972 PG&E changed its
' depreciation schedule for Unit 3 in two ways.
PG&E lowered its estimate of net salvage value from +2% to -10%, and PG&E reduced the estimated useful life from 35 to 30 years.
Even with these two changes, the Alliance points out that a fund of just $2 5 million 1
would have accrued over Unit 3's expected useful life.
The Alliance argues that in 1972 PG&E knew the cost of decommissioning Unit 3 would exceed $2 5 nillion.
Yet in the Alliance's view, PG&E failed to study the cost of decommissioning so that a more accurate depreciation rate could be fixed.
The Alliance points out that in 1974 the Elk River nuclear power plant was dismantled and fully decommissioned at a cost of
$6.1 million.
Despite this experience for a much smaller plant, the Alliance submits that PG&E recklessly continued to accumulate just
$2 5 million for Unit 3's eventual decommissioning.
The Alliance further claims that in 1974 PG&E was aware that the NRC might close Unit 3 Thus, the Alliance submits that PG&E had another good reason to undertake a thorough study of the decommissioning cost.
I In 1976, Unit 3's license was modified to effectively prevent further operation.
At this point, the Alliance believes any reasonable utility manager would have studied the decommissioning cost.
In 1978, PG&E finally did estimate Unit 3's decommissioning cost.
The 1978 estimate was $30 million.
However, even with the calculation of this figure, the Alliance asserts that PG&E did not 1
change the depreciation schedule for Unit 3 PG&E continued to collect enough money for a fund of just $2 5 million.
In 1979, PG&E raised its estimate of decommissioning cost l
to $32 37 million.
However, the Alliance observes that PG&E again 1
neglected to recover more funds for decommissioning.
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e t-A.83-09-49 ALJ/ed As a result, Unit 3 was removed from rate base in 1979 additional funds were not collected for decommissioning after 1979 The accrued funds through 1979 amounted to just $577,000.
Several years later in 1981, PG&E's consultants, Gibbs and Gibbs Hill, conducted an analysis of Unit 3's decommissioning cost.
is and Hill estimated the cost at $42 million which with escala the 358 million figure PG&E relies upon today.
The Alliance submits that PG&E's repeated failures to collect enough revenue for Unit 3's decommissioning had economic The Alliance claims that PG&E consequences for the ratepayers.
squandered an opportunity for ratepayers to accumulate interest Because of through an earlier accrual of a decommissioning fund.
PG&E's delay, the Alliance contends the ratepayers will be forced to d
pay more for decommissioning than they would have paid had PG earlier.
The Alliance further submits that PG&E's conduct was The Alliance argues that PG&E was obligated to collect inequitable.
decommissioning monies from the ratepayers that received power As a result, However, PG&E did not do this.
generated at Unit 3 ratepayers who have not and will not receive any benefits from Unit 3's operation are being asked to pay the full cost of decommissio The Alliance proposes that PG&E's shareholders should d
absorb the foregone interest of $29 million which could have accrue Under on a $30 million decommissioning fund from 1972 to present.
h lf this proposal the shareholders and ratepayers would each pay one-a If of the current estimated decommissioning cost of $5e million.
PG&E had prudently planned for the accumulation of a decommiss l
fund from 1972 onward, the Alliance believes that some S29 millio I
interest would be available today to offset the cost of l
decommissioning.
As an alternative, the Alliance suggests that PG&E's This amount shareholders should be required to pay $7,244,926.
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A.83-09-49 ALJ/ad 1
s represents the foregone interest which could have accrued on a S15 million fund.from 1974-1979 and on a 830 million fund from 1979-1985 The Alliance believes that these are the minimum decommissioning' funds which PG&E reasonably could have projected.
PG&E asserts that its method of accumulating a decommissioning fund was reasonable and the accepted procedure j
throughout the industry.
PG&E points out that no utility in the 4
country from 1972 to present has established the type of sinking fund advocated by the Alliance.
During this period, PG&E maintains there was great uncertainty about the eventual cost of decommissioning a nuclear power plant.
PG&E asserts that no utility manager or regulator could have reasonably foreseen what the present day cost of decommissioning is.
PG&E argues that the Alliance's recommendation is made with perfect hindsight.
The Alliance assumes that in 1972 someone could have known what the cost and duration of a decommissioning fund would be in 1985 PG&E contends that the Alliance simply has taken the 858 million cost estimated in 1985 and assumed -that PG&E should have planned for the accumulation of this exact amount back in 1972.
PG&E submits there is no basis for the Alliance's proposal.
PSD also opposes the Alliance recommendation.
PSD believes that ratepayers should pay the entire cost of decommissioning Unit 3 PSD asserts that until recently very little was known about the process of decommissioning.
The first full decommissioning of a commercial nuclear powerplant did not occur until 1974.
Thus, PSD
{
concludes that PG&E's accrual of a modest decommissioning reserve i
during the 1970's was not imprudent or unreasonable.
PSD also disputes the Alliance claim that ratepayers have I
been harmed.
PSD argues that from 1972 to 1985 ratepayers were j
enjoying the use of money which they would not have had if they had l
paid it into a decommissioning fund.
PSD maintains that the foregone i
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e A.83-09-49 ALJ/md interest identified by the Alliance is not a real loss to ratepayers.
PSD suggests that the Alliance is simply making an equity argument that the ratepayers who received the benefits from Unit 3 should also pay the costs.
With respect to equity, PSD points out there never is a PSD precise matching of costs and benefits in public utility rates.
notes that since the Humboldt area is electrically isolated, only Eureka customers actually received power from Unit 3 Yet the Alliance proposes that all ratepayers in PG&E's service territory should pay the decommissioning cost.
PSD submits that such equity problems are inherent in regulation and cannot be eliminated.
In response, the Alliance contends that there was a "real" The Alliance asserts the amount of money.
cost to ratepayers.
retained by each ratepayer was so small that there was no significant investment opportunity.
According to the Alliance, PG&E's ability to collect a large amount of money from all ratepayers created a commensurately greater investment opportunity.
The Alliance maintains that PG&E's failure to collect an adequate decommissioning fund did result in a real cost to the ratepayers from 1972 to 1985 With respect to its equity argument, the Alliance argues that it is unfair to ask consumers who never received any power from The Alliance Unit 3 to pay for the entire cost of decommissioning.
states that this "... sounds not just a little bit like the taking of property without due process of law..."
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m A.83-09-49 ALJ/md After reviewing the record and the parties' briefs, we do not find that PG&E's plans for decommissioning Unit 3-were imprudent-or unreasonable.
The methods and requirements for decommissioning nuclear power plants are still evolving today and were not well established in 1972.1 Even today, the method and cost for decommissioning Unit 3 are very speculative since the availability of an approved nuclear vaste repository will not be known before the late 1990's.
I During the 1972-1985 period, PG&E did update its decommissioning estimates.
PG&E's alleged failure to request correspondi'tg rate adjustments was not unreasonable in view of the uncertainty about decommissioning requirements.
We agree with PSD that PG&E's postponement of a decommissioning rate request had no real economic consequence to the ratepayers.
The foregone interest identified by the Alliance is a theoretical loss which in our view is offset by the theoretical savings realized by past ratepayers in lower bills.
We do recognize that in an ideal world of economic theory, costs and benefits are matched as closely as possible.
In fairness to the utility, such a matching should be made prospectively, not after the fact with perfect hindsight.
By the time PG&E was reasonably aware that decommissioning costs were substantial, a l
perfect matching of Unit 3's costs and benefits was not possible.
l And as pointed out by staff, due to the Humboldt; area's isolation i
from the rest of PG&E's system, the Eureka
- customers who received Unit 3's power should pay the decommissioning cost if a perfect l
I I The Alliance filed a Petition to Set Aside Submission and To Roopen the Proceedings for the Taking of Additional Evidence pursuant to Rule 84.
The Alliance would submit evidence on the information available in 1972-1973 on decommissioning.
However, the Alliance failed to meet the minimum requirement of Rule 84 to specify a material change of fact or law that occurred since the conclusion of the hearing.
Accordingly the Alliance's petition is denied.
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A.83-09-49 ALJ/sd Even the Alliance he.s not suggested 1
economic matching is sought.
that such an apportionment should be undertaken although in principle it would be consistent with the Alliance's argument.
Essentially the Alliance's equity argument divides past ratepayers who received power from ratepayers into two groups:
Unit 3 and future ratepayers who will never receive power from Unit l
Separating ratepayers into different vintages would be f
3 We doubt that the unnecessarily complex with undefined rewards.
l Alliance would desire past ratepayers who paid for PG&E's hydroelectric resources to charge future ratepayers the market value Yet the simple converse of the for the hydroelectric power.
f Alliance's equity argument would permii ratepayers who have paid for all the costs of a resource to receive all the benefits.
We will allow PG&E to collect from ratepayers the cost of As decommissioning the prudently constructed plant at Unit 3 decided in D.85-08-046 and later modified in D.85-11-046,. PG&E was imprudent in making plant modifications after the NRC issued its Since PG&E's shareholders are responsible for the May 1976 order.
cost of those modifications, they also are responsible for the cost of decommissioning those facilities.
Any additional decommissioning cost brought about by the installation of the plant disallowed for I
ratemaking purposes should be borne by PG&E's shareholders.
A decommissioning fund for Unit 3 should be collected over B.
a four-year period, the same time the allowed retirement cost is recovered. PG&E advocates a 15-year a.: - ual period for the decommissioning fund because this period coincides roughly with the PSD believes a 15-year remainder of Unit 5's original useful life.
PSD observes period has the additional advantage of flexibility.
that tax rulings may affect the revenue requirement of a PSD believes that such changed circumstances decommissioning fund.
may be more easily recognized over a longer 15-year accrual period.
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A.83-09-49 ALJ/ad The Alliance advocates a shorter period of two to four years.
The Alliance argues that a longer period of.15 years would i
offer less assurance about adequate funding, would be more costly to ratepayers, and would "vaste" equity.
The Alliance further notes that a shorter two to four-year period would provide adequate flexibility and would not cause any " rate shock."
We have addressed the decommissioning cost of Unit 3 in this proceeding so that we could review all expenses related to Unit 3 at one time.
PSD earlier requested that the issue of decommissioning Unit 3 should be addressed in OII 86.
We denied PSD's request because Unit 3 is in a unique position.
Unit 3 was closed in 1976 and will not operate again.
The other nuclear plants l
whose decommissioning expense is at issue in OII 86 are operating or expected to resume operation.
Thus, the criteria developed in OII 86 l
are not applicable here.
Our primary goal is to address all of Unit 3's expenses at once.
For this reason alone we will adopt a four-year period coinciding with the four-year amortization period ordered in D.85-08-046 for recovery of Unit 3's retirement expense.
C.
A cost monitoring system and an Independent Board of Consultants are unnecessary at this time.
l The Alliance submits that a cost monitoring system and an Independent Board of Consultants should be established now before the plans for decommissioning Unit 3 are fully developed by PG&E.
The Alliance asserts that an early review of PG&E's decommissioning plans I
is important "...because cost overruns usually begin in the planning i
i stages of a large p'roject."
i PSD points out that the actual decommissioning of Unit 3 I
will not occur for about 30 years.
Until then, PSD believes any
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system of cost monitoring would be useless.
PSD believes a cost monitoring system should be considered by the Commission when the decommissioning activity is imminent.
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a A.83-09-43 ALJ/md We agree with PSD that the establishment of a cost A thorough review monitoring system at this time would be premature.
of PG&E's decommissioning plans for Unit 3 should be undertaken after a nuclear waste depository becomes available for Unit 3's spent Until this occurs, PG&E cannot transport any nuclear waste fuel.
material from Unit 3 Any plans that PG&E, PSD, or an Independent Board of Consultants might make before a depository becomes available Thus, we will adopt PSD's suggestion would be somewhat speculative.
.that a review of PG&E's decommissioning plans should not take place Imminence is defined as the date on until the activity is imminent.
which an approved depository is made available for Unit 3's nuclear At that time the Commission shall determine whether a cost f
waste.
monitoring system and an Independent Board of Consultants are necessary or otherwise are appropriate.
Rates should be lowered to reflect the reduced Operation D.
and Maintenance (0&M) expense for Unit 3 and the sale of unused nuclear fuel.
PSD submits that once Unit 3-is placed in SAFSTOR, the PSD points out plant's O&M expense will be reduced by $3,889,000.
that PG&E does not dispute the amount of.this reduction for Unit 3 PG&E, however, maintains that increased O&M expense for Humboldt Eay Power Plant Units Nos. 1 and 2 (Units i and 2) will offset all but
$1,824,000 of the 33,889,000 reduced O&M for Unit 3 PSD argues that if PG&E believes O&M expense for Units 1 and 2 have increased, then PG&E should file an application requesting Until PG&E produces such a filing with additional rate relief.
adequate explanation of the increased expense, PSD believes PG&E's I
claim ia completely unsupported.
In response, PG&E contends that PSD has selected one test I
year estimate which was adopted and now exceeds the expected 1
j PG&E observes that it is not allowed to identify any test
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expense.
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A.83-09-49 ALJ/md i
i year estimates which-have been adopted and now fall short of the PG&E concludes that PSD's selective review of expected expenses.
expenses adopted in.a general rate case violates the principles underlying test year ratemaking.
Finally, PG&E emphasizes that the revenues it will collect PG&E 8'
under present rates will cover real costs for Units 1 and 2.
asserts that it has shown how increased manpower requirements for Units 1 and 2 will match the revenue no longer needed for Unit 3 We agree with PSD that rates should be lowered by
$3,889,000 as soon as Unit 3 is in a SAFSTOR condition.
We will adopt January 1, 1986 as the date on which Unit 3 shall be considered to be in SAFSTOR.
PG&E is correct in pointing out that individual expense itens considered in a test year ratemaking proceeding usually are not adjusted.
Unit 3's expenses, however, are being considered in this separate proceeding.
We are allowing PG&E to recover the increased expense of SAFSTOR even though this expense was not recognized in the last test year ratemaking proceeding.
It would be illogical to acknowledge an increased SAFSTOR expense for Unit 3 and at the same time to ignore the reduced O&M expense caused by the plant's placement in SAFSTOR.
We will adopt PSD's recommendation.
With respect to the S804,000 in revenue-from the sale of unused nuclear fuel, this amount should be amortized over the same four-year amortization period chosen for Unit 3's allowed retirement and decommissioning expense.
Findings of Fact 1.
PG&E has accumulated $577,000 for the decommissioning of Unit 3 2.
The current estimated cost for decommissioning Unit 3 is I
I 858 million in 1986 dollars.
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1 e; A'. 83-09-49 ALJ/md The method and cost of decommissioning Unit 3 were not well-3 defined in the 1970's.
PG&E's failure to collect a larger decommissioning fund-4.
wh'ile Unit 3 was operating was not imprudent or unreasonable.
PG&E's ratepayers are economically indifferent to the 5
timing of a decommissioning fund accrual.
A four-year accrual of a decommissioning fund is preferable 6.
since it matches the amortization period selected for Unit 3's retirement expense.
A cost monitoring system and Independent Board of 7
Consultants'need not be considered until the decommissioning activity is imminent.
When Unit 3 is placed in SAFSTOR, O&M expense for Unit 3 8.
vill decrease by $3,889,000.
9 PG&E will realize $804,000 from the sale of unused nuclear fuel.
This order should take effect on the date of issuance so 10.
- 1986, f.;
that the authorized rate charges can take effect on January 1, Conclusions of Law i
PG&E's shareholders are responsible for the cost of 1.
decommissioning plant facilities which have been disallowed for ratemaking purposes as imprudent expenditures.
If the Commission recognizes the increase in SAFSTOR 2.
expense, then it must recognize the reduction in O&M expense in fixir.c rates for Unit 3 i
EEElE IT IS ORDERED that:
Pacific Gas and Electric Company (PG&E) shall recover from 1.
its ratepayers the cost of decommissioning the prudently constructed i
plant at Humboldt Bay Power Plant, Unit 3 (Unit 3) over a four-year i
period.
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2.
PG&E shall submit to the. Evaluation and Compliance Division (E&C) and the Administrative Law Judge (ALJ) an estimate of'the I
decommissioning cost attributable to the imprudently constructed plant dI at Unit 3 Y
y 3
After E&C reviews and approves PG&I's estimate, PG&E shall file tariffs reflecting recovery of the allowed decommissioning cost, recovery of the allowed SA7STOR expense, the accrued decommissioning fund, revenue from the sale,of unused nuclear fuel.
If E&C does not agree with PG&E's estimate, then this matter shall be referred to the ALJ for resolution.
4.
If a tax ruling reducing the revenue requirement for the decommissioning fund is issued, then PG&E shall promptly file tariffs reflecting the reduction.
j 5
Ten days after the effective date of this order PG&E shall file tariffs for a reduction of $3,889,000 effective January 1, 1986 to
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reflect Unit 3's reduced operation and maintenance expense.
6.
PG&E shall submit to the Commission's E&C Division for reviev its plan for decommissioning Unit 3 when the decommissioning activity is imminent.
In this submittal, PG&E shall state whether in its view a cost monitoring system and/or Independent Board of Consultants are appropriate.
This order is effective today.
Dated December 4,1985, at San Francisco, California.
e DONALD TIAL President YICTOR CALVO PRISCILLA C. GREW 1
WILLIAM T. EAGLEY FREDERICK R. DUDA Commissioners l
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