ML20236E765

Forwards Clarifying Tech Specs Re Licensee Decommissioning Plan.Related Correspondence

ML20236E765
Person / Time
Site:	Humboldt Bay
Issue date:	07/24/1987
From:	Matt Young NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	Carpenter J, Lazo R, Morris P NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
CON-#387-4123 OLA, NUDOCS 8708030079
Download: ML20236E765 (7)

Text

__ _ _ _ _ .

! gkB RICQ

@.l#ED CORRESPONogugf3

1. o, UNITED STATES ., , . .

e  ! 7 g NUCLEAR REGULATORY COMMISSION 'lr ,l ' t s

, I WASHINGTON, D. C. 20555 o

% ,', , , , # July 24,1987 '87 JLt 28 All :05 Dr. Robert M. Lazo, Chairman Dr. James H. Carpenter.

Atomic Safety and Licensing Atomic Safety and Licen; sing Board Panet Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Peter A. Morris Ai imic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l

f in the Matter of PACIFIC GAS AND ELECTRIC COMPANY (Humboldt Bay Power Plant Unit No. 3' Docket No. 50-133 OLA ,_

Dear Administrative Judges:

Enclosed for your information is a copy of a staff letter, dated on July 23, 1987, regarding clarification of the technicai specifications j related to Licensee's decommissioning plan. Copies of the letter were I 1

transmitted to counsel for Licensee and Joint Interveners when the letter was issued.

Sincerel ,

Mitzi A. Y .ung /

Counse for NRC Staff

Enclosure:

As stated cc w/ encl: Gaye M. Barr Daniel E. Hauser Barry Keene Douglas H. Bosco Redwood Alliance cc w/o encl: Remainder of Service List G708030079 870724 O PDR ADOCK 05000133 G PDR )

[,,nic %., UNITED STATES

[ " ; v. 'I ,g NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555

.'1 ~t

.  ; e July 23, 1987

$[...../

Docket No. 50-133 l

Mr. J. D. Shiffer. Vice President Nuclear Power Generation, Licensing Pacific Gas and Electric Company 77 Beale Street, Room 1451 San Francisco, California 94106

Dear Mr. Shiffer:

1 1

SUBJECT:

REQUEST FOR ADDITIJNAL INFORMATION, HUMBOLDT BAY POWER PLANT UNIT No. 3 '

By letter dated April 29, 1987 we issued our Safety Evaluation Report (SER) for the Humboldt Bay Power Plant, Unit No. 3 Decommissioning. In that SER we determined that your Decommissioning Plan and proposed Technical Specifications (TS) were acceptable. Since that time, however, our regionL1 staff has reviewed your proposed TS with respect to their inspection programs and has concluded that certain changes would improve surveillance, clarify the TS requirements and reduce misuiiderstandings during these inspections. Enclosures 1 and 2 identify changes 'n the TS that Regien V and NRR staff agree are needed.

We have detennined tnat these changes should be made as part of our action on your proposed decommissioning plan. Therefore. we request your response within 30 days of the date of this letter.

The reporting and/or recordkeeping requirements contained in this letter l

affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.

Sincerely, Peter B. Irickson, Project Manager Standardization and Non-Power Reactor Project Directorate Division of Reactor Projects III, IV, V and Special Projects Office of Nuclear Reactor Regulation

Enclosures:

As stated cc w/ enclosure:

See next page 1

l

1 J

)

4 1 Yr. J. D. Shiffer l Pacific Gas and Electric Company Humboldt Bay Nuclear Power Plant  !

l CC l Philip A. Crane, Jr., Esq. Mr. Joseph 0. Ward, Chief Pacific Gas and Electric Company Radiological Health Branch Law Department State Dept. of Health Services Post Office Box 7442 714 P Street, Office Bldg. #8 San Francisco, California 94120 Sacramento, California 95814 l Chairman Director Humboldt County Board of Supervisors Energy Facilities Siting Division ,

l County Courthouse Energy Resources Conservation &

825 Fifth Street Development Comission Eureka, California 95501 1516 9th Street Sacramento, California 95814 Linda J. Brown, Esquire Donohew, Jones, Brown & Clifford Gretchen Dumas, Esq. ,

- 100 Ven Ness Avenue,19 Floor Public Utilities Comission l San Francisco, California 94102 of the State of California (

5066 State Building U.S. Environmental Protection Agency San Francisco, California 94102 Region IX Office l ATIN: Regional Radiation Representative Public Affairs Officer l 215 Freemont Street Region V I Sen Francisco, California 94105 U.S. Nuclear Regulatory Comission i i

1450 Maria Lane Regional Administrator Walnut Creek, California 94596 Nuclear Regulatory Comission Region V 1450 Maria Lanes Suite 210 Office ef'Intergovernme'ntal Walnut Creek, California 94596 Management State of California Michael C. Sherwood, Esq. 1400 10th Street, Room 108 '

Sierra Club Legal Defense Fund, Inc. Sacramento, California 95814 EN4 Fillmore Street San Francisco, California 94115 Bruce Norton, Esq.

2002 East Osborn Dr. Perry Amino +.o Phoenix, Arizona 85064 Dep5rtment of Conservation Division of Mines & Geology 1416 9th Street, Room 1341 Sacranento, California 95814 Scott L. Fiedler, Esq.

517 Third Street, Suite 14 Eureka, Cal 1fornia PE501

i l

1 Enclosure 1 I

I REQUEST FOR ADDITIONAL INFORMATION HUMBOLDT BAY UNIT NO. 3, TECHNICAL SPECIFICATIONS FOR DECOMMISSIONING Paragraph Comment II.B. A local area map defining the unrestricted areas used for l offsite dose calculations for gasesus and liquid effluents I should be included in TS.

In addition, a site map clearly defining the restricted areapursuantto10CFR20.3(a)(la)shouldbeincluded.  !

II.C. What activities, such as decontamination and/or removal of l structures, systems and components are permitted by the i description titled " Principal Activities"? Reference to ,

Regulatory Guide (R.G.) 1.86 Section C.5 may be used. l III.B.I. "A thorough visual inspection" lacks specificity. This might be acceptable if a procedure was required by section l VII.E. which provide for consistent insper.tions on a continuing basis.

III.B.2. The stated 10.5 feet elevation above mean low low water level may become a source of confusion.

For clarity the TS should also specify the minimum level from the top of the spent fuel pool liner.

The stated gap water level of +9 inches above mean low low water level may also be a source of confusion. Level -

should be specified with respect to a fixed location on the spent fuel pool.

III.B.2.b. TS requires that the Spent Fuel Pool water shall be sampled and analyzed at least once per quarter to determine water quality.

Since water quality appears to be an important factor in preventing BORAL can deterioration (ref. Inspection Report No. 50-133/87-01), the pool water should be sampled more frequently than quarterly.

Table III-2 The " acceptable range" column should be titled " limits" for clarity.

,' l i* l Paragraph Comment Table III-2 An action statement to require use of the cleanup system above the limiting value should be provided. If the activity canr.ot be reduced to less than the limit prior to  !

the next required sample, a 30 day report to NRC should be made. If the peak activity for any measurement exceeds a ,

value indicative of 10% clad degradation under static '

conditions an innediate report to NRC should be required.

IV.B.3.b. The report should 90 to the Regional Administrator and should describe the compensatory measures and schedule of corrective actions.

IV.B.3.c(1) A seven day verification of water level is reasonable if a low water level alarm setpoint is added to the TS. j IV.B.3.c.(8). A specific gravity number should be stated in the TS.

IV.B.4.a. Fire Hose Stations listed on Table IV-1 should be operable I at all times.

l V.A.4. Offsite dosimeters should have their location docamented l

4 on a map as part of the TS. I Offsite water sampling should be specified (location and i radionuclides). The sampling should be in a downstream l

location with respect to surface water and groundwater. 1 i

V.A.6 Onsite sampling should be described a>s to radionuclides  !

sampled and the locatien.

- {,

V.B 1 The TS should require that the Offsite Dose Calculations l Manual (0COM) be in compliance with R.G. 1.109.  !

V.B.2. One purpose of the process monitor is to detect inadvertent discharge of radioactive effluent. Therefore, the alarm setpoint must be set lower than tne 10 CFR 20 i Appendix B concentration at the site boundary. Specify  ;

the setpoint in the TS.  ;

V.B.3.d. TS should specify that area radiation detection instruments be calibrated at least annually. 1 V.B.3.e. TS should specify that portable radiation detection l instruments be calibrated at least annually.

i l

l I

I

m -

l

)

)

t 1

i Paragraph Comment

]

V.B.6. TS should require that ground water be monitored for tritium. Thirty day reporting levels should be established for ground water parameters.

VI.A.1 The maximum filter size should be specified in micrometers for radwaste filters.

l VI.A.2. TS should specify that radioactive waste should not be stored for greater than five years. See Generic Letter 80-38.

j VI.B.I. The limits expressed in 40 CFR 190 (25 inRem per year) should also be specified. l

\

VII.C.4.d. TS sh'ould include training on 10 CFR 19, 20, 61 and 71 as I l a minimum. A retraining frequency should be specified.

l VII.E. Procedures list should include calibration of instruments, effluent releases, transportation and emergency plan implementing procedures.

VII.F. " Periodic drills" should be replaced with " Drills / exercises described in the Emergency Plan". ,

VII.H.1. The annual report should go to the Regional Administrator, Region V with a copy to NRC Document Control Desk. The date for submittal of the annual report should be specified (normally within 90 days after January 1 of each year).

VII.H.2. The Semiannual Effluent Release report should be submitted l to the Regional Administrator with a copy to the NRC Document Control Desk.

VII.I.1.f and g TS should specify requirements for leak testing and I inventories of sealed sources. Enclosure No. 2 provides a TS example for guidance.

1

1 Enclosure ?  ;

i

\'

i GUIDANCE FOR T.S. ON SEALED SOURCE LEAK TESTING 4 L Each sealed sourca containing radioactive rnaterial in  !

excest of 100 microcuries of beta and/or gamma  ;

emitting material or 10 micro:Jries of alpha-emitting i material shall be tested for leakage and/or f contamination. l l

If the test reveals the presence of contamination in j excess of 0.005 microcuries of removable contamination, the source shall be immediately i removed from service and decontaminated, repaired, or I disposed of in accordance with commissica regulations. A report shall be prepared and 1 submitted to the Regional Administrator, U,5. Nuclear j Regulatory Commission, Region V within 30 days of the I date the leak test result (greater than 0.005- l microcuries) is known. The report shall specify the  ;

source involved, the test results, and corrective action taken. Records of leak test results shall be {

a kept in units of microcuries.

{

2. Test Requirements - Each sealed source shall be  !

tested for leakage and/or contamination by the  !

licensee or other persons specifically authorized by j the Commission or an Agreement State. The test '

method shall have a detection sensitivity of at least 00 '

O.005 microcuries,

3. Inspection and Tests - Each sealed source (excluding t

l l

startup sources and fission detectors previously '

subject to core flux) shall be tested for leakage and/or contamination as follows:

, (a) Sources in Use - At least once per 6 months for '

all sources containing radioactive material, j other than hyarogen 3, with a half-life greater l than 30 days and any form other than gas.

(b) Stored sources not in use - Each sealed source and fission detector shall be tested prior to use or transfer to another licensee unless tested within the previous 6 months. Sealed I sources and fission detectors transferred without a certificate indicating the last test l date shall be tested prior to being placed into use.

4. All sealed sources containing quantities of radioactive material in excess of those specified in 10 CFR 20 Appendix C shall be physically inventoried at least every 365 days.

If a source cannot be located during the inventory then a report must be submitted pursuant to 10 CFR 20.402.

L