ML070160090

Notice of Consideration, Modification of Physical Security Plan (PSP)

ML070160090
Person / Time
Site:	Humboldt Bay
Issue date:	01/22/2007
From:	John Hickman NRC/FSME/DWMEP/DURLD/RDB
To:	NRC/FSME
John B. Hickman, 301-415-3017
References
Download: ML070160090 (5)

Text

January 22, 2007MEMORANDUM TO:Biweekly Notice CoordinatorFROM:John B. Hickman, Project Manager /RA/Reactor Decommissioning BranchDecommissioning and Uranium Recovery Licensing Directorate Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs

SUBJECT:

REQUEST FOR PUBLICATION IN BIWEEKLY FR NOTICE - NOTICEOF CONSIDERATION OF ISSUANCE OF AMENDMENT TO FACILITY OPERATING LICENSE, PROPOSED NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION, AND OPPORTUNITY FOR A HEARINGPacific Gas and Electric Co., Docket No. 50-133, Humboldt Bay Power Plant (HBPP), Unit 3Humboldt County, CaliforniaDate of amendment request: May 17, 2006Description of amendment request: The licensee has proposed to modify the Physical SecurityPlan (PSP) to allow leaving certain security posts temporarily under emergency conditions requiring personnel to evacuate occupied plant areas for their health and safety.

Basis for proposed no significant hazards consideration determination: As required by 10 CFR50.91(a), the licensee has provided its analysis of the issue of no significant hazards consideration, which is presented below:

(1)Does the change involve a significant increase in the probability or consequences of anaccident previously evaluated? Response: No.

Allowing the security posts and monitoring requirements of PSP, Sections 3.1.4 and 4.3,and Table 7-1, to not be continuously maintained has no impact on the probability of an accident from occurring, especially acts of nature such as earthquakes and tsunamis.

Biweekly Notice Coordinator2The HBPP Defueled Safety Analysis Report, Appendix A, and NRC Safety EvaluationReport (SER), Section 10, dated April 29, 1987, evaluate various accidents at HBPP.

Because all fuel has been removed from the reactor vessel and stored in the spent fuel pool, the majority of accidents analyzed pertain to events that could only affect spent fuel or the spent fuel pool. All accidents affecting spent fuel or the spent fuel pool do notrequire security personnel action to protect the public health and safety, or to maintain offsite radiological doses well within regulatory limits. In addition, NRC SER, Section 10.7, "Impact of Tsunami Flooding," analyzes the impact of tsunami flooding. That analysis identifies a likely impact of the tsunami to be a release of the radwaste tank radionuclide contents to the bay and some damage to the reactor building. For both situations, no security personnel action is required to maintain offsite radiological doses well within regulatory limits.Allowing the security posts and monitoring requirements of PSP, Sections 3.1.4 and 4.3,and Table 7-1, to not be continuously maintained temporarily, under emergency conditions, does not create problems that could increase the consequences of an accident. The primary function of the manning and monitoring requirements of PSP, Sections 3.1.4 and 4.3, and Table 7-1, is to monitor, detect and assess unauthorized intrusion into the protected area, and has nothing to do with the probability or consequences of plant accidents.If security personnel evacuate PSP, Section 3.1.4 and Table 7-1, security posts during atsunami, those security personnel will be able to return to the PSP, Section 3.1.4 and Table 7-1, security posts after the tsunami and assess damage or intrusion by observing alarms and/or physical conditions as well as resume implementation of security post and monitoring requirements of PSP, Sections 3.1.4 and 4.3, and Table 7-1. In addition, upon evacuation, security personnel notify offsite security backup personnel of the evacuation and the need for the offsite personnel to remotely monitor HBPP security system alarms. Conversely, if security personnel remain at the PSP, Section 3.1.4 and Table 7-1, security posts during a tsunami and become injured, those security personnel would be unable to assist in the resumption of implementation of security post and monitoring requirements of PSP, Sections 3.1.4 and 4.3, and Table 7-1. Therefore, not continually manning the PSP, Section 3.1.4 and Table 7-1, security posts during a tsunami does not increase the consequences of the tsunami. (2)Does the change create the possibility of a new or different kind of accident from anyaccident evaluated? Response: No.

As discussed in the response to Question 1 above, none of the analyzed accidentsrequire security personnel action to keep offsite radiological doses well within regulatory limits. In addition, allowing security personnel to not continuously maintain security post and monitoring requirements of PSP, Sections 3.1.4 and 4.3, and Table 7-1, after an emergency situation has occurred has no impact on the possibility of a new or different kind of accident from occurring. The primary function of the manning and monitoring requirements of PSP, Sections 3.1.4 and 4.3, and Table 7-1, is to monitor, detect, and assess unauthorized intrusion into the protected area, and has nothing to do with the possibility of a different kind of plant accident occurring.

Biweekly Notice Coordinator3(3)Does the change involve a significant reduction in a margin of safety? Response: No.

NRC SER, Section 10.8, "Accident Analysis Conclusions," summarizes theconsequences from accidents in terms of offsite radiological doses. SER, Section 10.8, includes the statement, "The (NRC) staff has determined that offsite radiological consequences due to a tsunami are within acceptable dose guideline values." As discussed in the response to Question 1 above, none of the analyzed accidents require security personnel action to keep offsite radiological doses well within regulatory limits.

Therefore, allowing security personnel to not continuously maintain security post and monitoring requirements of PSP, Sections 3.1.4 and 4.3, and Table 7-1, after an emergency situation has occurred has no impact on the margin of safety. The NRC staff has reviewed the licensee's analysis and, based on this review, itappears that the three standards of 10 CFR 50.92(c) are satisfied. Therefore, the NRC staff proposes to determine that the amendment request involves no significant hazards consideration.

Attorney for licensee: Mr. Antonio Fernandez, Esquire, Pacific Gas & Electric Company, PostOffice Box 7442, San Francisco, CA 94120 NRC Branch Chief: Claudia Craig Biweekly Notice Coordinator3(3)Does the change involve a significant reduction in a margin of safety? Response: No.

NRC SER, Section 10.8, "Accident Analysis Conclusions," summarizes theconsequences from accidents in terms of offsite radiological doses. SER, Section 10.8, includes the statement, "The (NRC) staff has determined that offsite radiological consequences due to a tsunami are within acceptable dose guideline values." As discussed in the response to Question 1 above, none of the analyzed accidents require security personnel action to keep offsite radiological doses well within regulatory limits.

Therefore, allowing security personnel to not continuously maintain security post and monitoring requirements of PSP, Sections 3.1.4 and 4.3, and Table 7-1, after an emergency situation has occurred has no impact on the margin of safety. The NRC staff has reviewed the licensee's analysis and, based on this review, itappears that the three standards of 10 CFR 50.92(c) are satisfied. Therefore, the NRC staff proposes to determine that the amendment request involves no significant hazards consideration.

Attorney for licensee: Mr. Antonio Fernandez, Esquire, Pacific Gas & Electric Company, PostOffice Box 7442, San Francisco, CA 94120 NRC Branch Chief: Claudia CraigDISTRIBUTION

DCD R/FRidsOgcMailCenterRidsRgn4MailCenter JHickmanCCraigKMcConnellML070160090OFFICEDCD/PMDCD/LAOGCDCD/SCNAMEJHickmanTMixonJHullCCraig DATE1/18/20071/18/20071/22/20071/18/2007OFFICIAL RECORD COPY