ML20125C994
| ML20125C994 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 12/31/1984 |
| From: | Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Zwolinski J Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20125C784 | List: |
| References | |
| FOIA-85-007 NUDOCS 8506120218 | |
| Download: ML20125C994 (78) | |
Text
---
- l
\ i ,/
i .
l QEQ,31 M MEMORANilllM FOR: .lohn A. 7.wollunki, Chief Opet'atlug Reacturn liianch #'s Division of Licensing FROM: Frank A. Wenslawski. Chief Emergency Preparedneau and Radiological o Protection Branch Region V SUBJ ECT: REVIEW OF llUMBOI.DT llAY DECOMMISSIONING Pl.AN We have completed our review of the ilumboldt Bay Power Plant Unit 3 Decommissioning Plan. This review was primarily focused upon the Iteenace's proposed technical specifications with a cursory review of the plan and environmental report. Our primary cencerns are that the technical specifications issued with the possession only license provide an adequate level of detail and enforceability. Our comments are provided as an enclosure.
We request the opportunity to commeat again, prior to issuance of the possession only license and revised technical specifications.
If you have any questions concerning the enclosed information, please contact the Region V Projec* Inspector, Conrad Sherman at (FTS) 453-3890.
/ Id 6*'
Frank A. Wenslawski, Chief Emergency Preparednens anil Radiologleal Prot ce t lou tiranit h
Enclosure:
An stated 0506120210 050214 PDR FOIA SHAPLEN05-007 PDR RV ,,s
- 1 .
Shennan Yuh\s Wenskawski e
?!!)on J
"!^
m[2f8'l
, ENCLOSURE 1 7
Comments concerning Technical Specifications for Possession Only License Paragraph Comment I!1.B.2.a Clarify the meaning of the spent fuel pool water level elevation.
IV.A.2 Should the term capacity be replaced with ' minimum inventory' ?
V.A.1 The design description appears to indicate that a gamma scintillation detector monitoring a particulate filter is used for noble gas detection; this should bc
, clarified.
A noble gas detection cl.annel with adequate sensitivity for Kr-85 should be provided as the present monitor is insensitive to this isotope. A requirement for a particulate monitoring device as the proposed specification describes should be retained.
An operating spare for the Noble Gas channel may be warranted while a backup grab sample capability is all that is necessary for the particulate channel.
What is the basis for the proposed range for the stack gas monitor?
V.A.2 The sensitivity of the waste system vent header monitor in uC1/cc/mR/hr should be described. It is not necessary that this be included in the specification .
What is the basis for the proposed range of the vent header monitor?
V.A.3 The range and sensitivity of the liquid offluent discharge radiation monitor should be deserthed in the npeeltication.
Actions to he taken when the monitor in out of service are not included in thin specification.
Include an apprepriate ireviuency such as daily or when a release is in progress for these actions.
V.B.! Ilow is the release rate specitled. 0.05 Curies per second, related to 10 CFR 20 or 40 CFR 190 limits?
V.B.2.B Clarify the term Cross Beta Soluble Activit h Table III-2 V.B.3 Actions to be taken when the monitor is out of service
! are not included in this specification. '
l When the monitor in out of nervice, the licensee nhould be required to verily the release by analysia. of duplicate independent samples and independent verification of the valve lineup prior to the activity being releaned.
V.B.5 Should the '>00 milli rem per year he replaced with 25 millirem
. per year?
l.
VI.B.I.a Should 10 CFR 20 be replaced with 40 CFR 1907 VII.C.! This specification contains no requirements for i nill v idua l o qua lil led in s.nllat lon pi ot er i line.
When work (other than security walkthroughs or visual inspections) is being performed in radiologically controlled or restricted areas or on contaminated equipment, the licensee should be required to include onsite at least one individual qualified in radiation protection pursuant to specification VII.C.4.e (to be added).
VII.C.4 The proposed specification does not describe the required training for radiation protection technicians. '
Consider addition of a requirement ( V11.C.4.e ) that a training rogram for radiation protection techniciano an described on pages 4-20 to 4-23, ucction 4.3.3.3 of the SAFESTOR Decommissioning plan dated July 1984 be included in the technical specifications.
VII.C.4.c Is an AhSi N 18.1 retraining program apprepriate for a tacility in this statunt V11.F.1 Change " prepared and adhered to" to " established implemented and maintaineil".
Include as F.I.g., Radiation protection Activities or change F.1.K co include the requirenent that procedures be " prepared, approved and adhered to".
i j
- e
- d -
. 4,0'!'F7b '
%, ,c!
'~a pg x, . %-
4., .
. N a . c ' : ', z, P
DOCKET No. 50-133 / .
AFFENDIX A
. TO OPERATING LICENSE NO. DPR-7 TECHNICAL SPECIFICATIONS . !
FOR .
FACIFIC GAS AND ELECTRIC CWFANY EtJMBOLDT BAY F0WER FLANT
. UNIT NO.'3
. DATE: ' - - . - "'. '*'9 5//3 Sird e
e S
t
, -go .
3s.y
, M[f'.l '
- 2. .
/y
( TABLE OF CONTE"TS 4
PACE I. INTRODUCTION I-1 A. Scope I-1 B. Modes of Operation I-1
- 1. Power Operation I-1
- 2. Refueling Operation I 3. Cold Shutdown ,
I-2 II. SITE 11-1 A. Location 11-1 B. Exclusion Area 11-1 C. Principal Activities 11-1 III. CONTAINKENT 111-1 A. Design Features ,
III-1
- 1. Dry Well 111-1 I
- 2. Suppression Chamber and Pool III-2
- 3. Emergency Core Cooling Systems III-3
- 4. Refueling Building III-5 5 .,' Refueling Building Ventilation System III-6
- 6. Dry Well and Suppression Chamber IAskage Rate .
Monitoring System .
III-7 B. Operating Limits and Requirements III-7 7 1. Dry Well and Suppression Chamber Testing '
and Inspection . III-7
- 2. Integrated 1.eakage Rate Testing III-7
- 3. Containment Modification Retest III-8
- 4. Leakage Rate Monitoring During Power Operation III-8
- 5. Penetration Closure Testing III-9
. 6. Containment System Inspection III-10
- 7. Dnergency Core Cooling Systems III-10 ,
a
- 8. Refueling Building Testing III-11
. 9. Retualing Building Ventilation System III-11 s 10. Containment Requireeints 111-11
- 11. Changes in Dry Well ed Suppression Chamber Penetrations III-13 Tab 1'e III-1, Dry Well Penetrations 111-14 Table III-2, Suppression Cham'er Penetrations 111-16.
. Table 111-3, Refueling Building Personnel and Equipment Entry and Ventilation System Penetrations III-17
-. .-. - ~ . . - . . - . - . -
d-e' ' /L , ,
./-
- gg,
- I -
PACE y(
IV. NUCLEAR STEAM SUPPLY AND TURBINE PLANT SYSTEMS IV-1 A.. Design Features I '
IV- I'
- 1. Reactor
- IV-1
- a. . Vessel IV-1
- b. Vessel closure -
IV-1 ,
. c., safety Valves IV-1 '
- d. Vent Valves -
IV-1
- e. Vessel Support IV-1 -
- f. Vessel Internals , IV-2 ,
- g. Control Rod Guidance IV-2 3 '
- h. Control Rod Drive Thimble Support IV-2
, i. Leakage Detection IV-2 '
2'. ' Normal Reactor Cooling Systems IV-2 ,
- 3. Emergency Reactor Cooling Systems -
IV-3 ;
- a. Emergency Condenser IV-3 r
- b. Emergency Core Cooling Systems IV-3 i 4. Reactor Clean-Up System IV-3 ,
5., Turbine Plant Systems u IV-3
- a. Main Steam Line IV-3
- b. Turbine Generator Unit *
'IV-4
, c. Main Condenser IV-4 *
- d. Turbine Steam Bypass System IV-4
- e. - Condensate and Feedwater System IV-4 ,
f . f. Closed Cooling Water System IV-5
\. ,
- g. Circulating Water System IV-5
- h. Makeup Water' System IV-5 ' l
, 'i. Instrument Air System IV-5 -
4., .
- 6. Shielding IV-5 B. Operating Limits and Requirements IV-6
- 1. Vessel Material Sample Program IV-6 l 2. Minimum Vessel Temperature - IV-6
- 3. Vessel Heatup and Cooldown Rates IV-6
- 4. Primary System Inspection -
IV-6 f
- s 5. Safety, Valves. IV-6
- 6 .~ Emergency Condenser IV-6
- 7. Reactor Water Quality During Power Operation IV-6
' Table IV-1, Reactor Vessel Nozzles IV-7
- Table IV-2, Reactor Water Quality Limits for Pwer Operation .
, IV-8 V.' REACTOR' CORE . V-1 -
A. Design Features V-1
$ # , 1. Mechanical Design of Core Components V-1
- a. Fuel Assemblies V-1
- b. Control Rodi and Drives V-1 i
- c. Poison Curtains
- V-3
- d. Liquid Poison System V-3
, 2. Principal Calculated Thermal Hydraulic and
. Nuclear Characteristics -
V;4
. 0
, iff O .
PACE
/ .
, B. Operating Limits and Requirements v.4
- 1. Reactor Power Level v.4
- a. Refueling y.4
- b. Power Operation . v.4
- c. Rate of Change of Reactor Power During Power Operation -
V-5 .
- 2. Control Rod System V-5
- a. Core Shutdown Margin V-$
- b. Control Rod Exercising During Sustained ,
Power Operation V-5
- c. Control Rod Performance Tests During Refueling Outages V-5
- d. Control Rod Following Checks V-6 s
- e. Control Rod Drive Temperature Limit V-6
- f. Removal of a Control Rod and/or Drive from E a Cell Containing Fuel V-6
- g. Abnormal Behavior of the Control Rod System V-6
- 3. Liquid Poison System V-7 L
- 4. Reactivity Coefficients V-7 ;
- 5. Reactivity Additions During Power Operation V-8 -
- 6. Reactivity Additions Du.Ang Core Alterations V-8
- 7. Storage and Transfer of Fuel Assemblies V-8
- 8. Maximum Fuel Burnup V-9
'TtFle V-1 Fuel Assembly Mechanical Design V-10 Table V-2 Principal Calculated Thermal and Hydraulic Characteristics V-Il
. Table V-3 Principal Calculated Nuclear Characteristics V-12 Figure V-1 Operating Core Configuration V-13 Figure V-2 Type I Fuel Assembly V-14 Figure V-3 Type II Fuel Assembly V-15 (
VI. '
REACTOR PROTECTION SYSTEM . VI-l
. A. ' Design Features VI-l
- 1. Reactor Safety System VI-l 2., Reactor _ Instrumentation VI-l
- a. Startup Channels VI-l .
- b. Intermediate Range Channels VI-l .
- c. Power Range Channels VI-2
. d. In-Core Flux Monitors VI-2 i e. Process Instrumentation VI-2
. 3. Haster Reactor Ewitch VI-2
- 4. Control Rod Withdrawal Permissive System VI-3
[ 5. Refueling Building High Differential Pressure
. , Protection System VI-3
- 6. Emergency Condenser Control VI .
i iv. k
+
PACE
.. 7. Electrical Systems VI-3
- a. 115 Volt A-C Preferred Power System VI-4 '
- b. Emergency Section, 480 Volt A-C System VI-4
- c. 125 Volt D-C System VI-5 .
B. Operating' Limits.and Requirements VI-5
- 1. Reactor Safety System VI-5 ,
- 2. Reactor Instrumentation VI-5
, s. Startup Channels VI-5 -
- b. In-Core Flux Monitors VI-6 '
- 3. Master Reactor Switch VI-6
- 4. Control Rod Withdrawal Permissive System VI-6
?
- 5. Refueling Building High Differential Pressure
- Protection System VI-6 i 6. Emergency Condenser Control System VI-7
'7. Electrical Systems VI-7 E
~
Table VI-1 Reactor Safety System for Power Operation VI-8 Table VI-2 Reactor Safety System for Refueling Operation VI-9 i
,VII. MONITORING SYSTEMS VII-1 A. Design Features VII-1
( 1. Air Ejector Off-Gas Mo.titoring System VII-1
- 2. Stack Gas Monitoring System VII-1
- 3. Emergency Condenser Vent Monitors VII-1 ,
- 4. Liquid Waste System Vent Monitor VII-1
- 5. Process Water Monitors VII-2 -
- 6. Refueling Building Isolation Monitors VII-2
- 7. Area and Portable Monitoring Equipment VII-2.
- 8. Off-Site Environmental Monitoring Stations VII-3 ,
B. Operating Limits and Requirements VII-3
- 1. Air Ejector Off-Gas Monitors VII-3
- 2. Stack Gas Monitoring System VII-3
- 3. Emergency Condenser Vent Monitors VII-3
- 4. Liquid Waste System Vent Monitor VII~3
- 5. . Refueling Building Isolation Monitors VII-4
- 6. Area Monitors and Portable Monitoring Equipment VII-4
~*
- a. Refueling Building Monitors VII-4
- b. Caisson Access Shaft Monitors 'VII-4
- 7. Of f-Site Environmental Monitoring Stations VII-4 VIII-1 VIl{. WASTE DISPOSAL SYSTEMS A. Design Features VIII-1 E
- 1. Liquid Radioactive Waste VIII-1 L. Solid Radioactive Waste VIII-2
- 3. Gaseous Radioactive Waste VIII-2
- a. Air Ejector Off-Gas System
- VIII-2
, b. Gland Scal. Condenser and Condenser Mechanical Vacuum Pump Exhaust System VIII-3
f
'VIII- 4 I 3. Operating 1.ibits med Requirc=ents . .
- VIII-4 i
- 1. Liquid Radicactive Weste VIII S
- 2. Solid I!:dio ctive h'asta VIII-5 i
- ' ,' Casso6s nadicaccive Waste
- 3. VIII-5
- 4. Air Ejector of f-ibs System VUI-5
- 5. cas Treatment System
- Page IX. ADMINIT.T TAT!*7! CONT'.0!.S '
. Ix 1
- A. Responsibility ,
- IX-1 3.' off Site Organt:ntion IX-1 ;
> C. Plant orscnization .
IX-4
- D. Review and Audit Ix E. Reportable Cccurrence Actica .
IX-9a .
- F. Operatin6 Procedures .
IX-10
.G. Site E=argency Plss .
I B. Operational Tasti=g of Nuciaar '
IX-10
. Safeguards Systams * . .II-11
.l *
'I. Reporting Require = ants. ,
IX-17 J. Record Retention .
IX-18 K. Radiation Protection Program - .
L. Deleted IX-18 M. High Radiation Area l
Table IX 1 Cparationsi Testing of Nucle:r Safeguards Systems Fata i 'i ' .' ..
X.
- PLANT 71R2 PROTICTION SYSTZ'!S SPEC!?ICATIOt:5
.. - %-1 A. Fire Suppression -
4
- X-1 Water Systa=
- 1. X-3 i
- 2. Spray and/or Sprinkler System X-5
- 3. C02 Systen X6 ,
- 4. Tire Hosa Stations X-6
- 3. EenetrationFireBarriers .
t
! ?_ase.t.
X-7
'.A. -l Fire Suppression Systems ~
. . X-7 .
4*- '
3.'
Penetratica Fire Earriers .
X-8
'~
Table X-1 Linit.3 Building Tire Hose Stations .
l
- - . s. .
i
(. '
i
- , e i(
i D
Amend:nent No. [. h, 17 1 .
I .
.w. en-,, - , .,,..,,,,,,-,-_,n,n,,n-_,.... . _ , _ , n,._,--,,,.__,___ ,,m - , ~ . .., _ ,,_ ~----.__ ,-.-_, ,
- s
. P 1-1 INTRODUCTION A A. SCOPE s
These Technical Specifications set forth the principal design features and ,
operating limits and requirements which have an effect on the safety of operation of Unit No. 3 (the Unit) at Pacific Cas and Electric Cogpany's (the Company) Humboldt Bay Power Plant (the Plant). ,
Section II of these Technical Specifications describes the site. Sections III through VIII describe the containment system, the nuclear steam supply I and turbine plant systems, the reactor core, the reactor protection system, the monito' ring systems, and the waste disposal systems. Each of.these Sec-tions consists.of:
, 1. A description of the design features which have important nuclear safe-
- guard implications. No change shall be made in these design features
. without prior AEC approval; except that where quantities of equipment ;
are stated, the number given is the minimum permissible, and additional
! units may be installed without prior AEC approval. Dimensions given in these descriptions are subject to normal manufacturing tolerances, un-less specific tolerances are stated. Calculated thermal, hydraulic, and nuclear characteristics of various systems are also given. .
- 2. A list of the operating limits and requirements which are significant -
- from the standpoint of nuclear safety. Whenever a condition occurs which requires corrective action to assure operation within these i - limits and requirements, such action shall be taken immediately. If '
the condition cannot be corrected in a timely manner, steps shall be taken to place the Unit in the cold shutdown condition in a manner consistent with safe operating practice.
Section IX of these Technical Specifications covers administrative and pro-cedural safeguards, including the review of proposed changes in design and operating limits, requirements and procedures, and presents procedures for normal and emergency operation of the Unit.
B. MODES OF OPERATION Operating limits and requirements for a number of systems depend on the mode of operation of the reactor. These modes are defined as 'follows:
- 1. Power Operation - Power operation is considered to commence at the time contro'1 rod withdrawal begins during a cold startup (as described in Section IX) and is in ef fect until reactor water temperature is reduced below 212*P during the subsequent shutdown.
- 2. Refueling Operation - Refueling operation is considered to commence at the time reactor water temperature is reduced below 212*F during a shutdown ,
from power operation, and is in effect until that next power operation!
startup except for those periods when the reactor is in the cold shutdown condition defined in (3) below. .
[* ,
e
r'
- 1-2
- 3. Cold Shutdown - The reactor is in the c'old shutdown condition when-t ever the following requirecents are met:
- a. All control rods in cells containing fuel assemblies are fully'
, inserted in the core. Rod withdrawal is prevented by the keylock master reactor switch which shall' be in the " Shutdown" position
. or by discLlind cite control rod withdrawal s /stem. roc 5.cy to this
. switch chall be conicolled by the Shift Foreman. ,
- . b. The core shutdown margin requirement (described in Section V) can ,
be demonstrated.
- c. The reactor is at atmospheric pressure.
Specific containment requirements for all rodes of operation are described in Section III.
e e
0 e
e s
E 6
- e b
6 a
9 e
e o
I e 4
O e
k
( .
9
F a /
11-1
' SITE
/ A. I,0 CATION The Urtit shall be located in Humboldt County, California, approximately 4 miles southwest of the center of the city of Eureka. on a 142.9 acre ~
site which shall be owned and controlled by the Company. * ,
B. EXCLUSION AREA The exclusion area shall comprise the entire Plant site. Ingress and egress shall be controlled by the company. The distat.a from the reactor to the nearest site boundary shall be 700 feet.
L I
C. PRINCIPAL ACTIVITIES
' The principal activities on the site shall be those related to the generation an transmission of electric power and the associated ser-
- vice activit.es. The Unit shall generate electrical energy by conver-sion of the sal energy produced by a controlled nuclear fission process.
This activity shall require the storage, utilization, and production of special nuclear materials and byproduct materials. The Unit shall be a part of the Plant and shall be located adjacent to two conventional, oil or gas fired, 50,000 kilowatt steam turbine generator units.
\ -
9 s
9 9
e 9
6 e
t O
O O
9 0 .
, I
t .
da. .
pI-5 the cafety system - and reactor pressure is or drope below 150 i i*
psig. For such an event the follouing operations shall tahc place automatically: ,
. (a). The air operated valve in the line between the Plant fire protection system and the shutdown system shall open. -
(b) The shutdown system motor operated supply valves shall open. ;
'~ '
(c) The plant fire pumps shall start sequ'ntially. e In EdMeio,"~the n coincideTeal occurrence of ' reactor water low *
, level, dry well high pressure and loss of feedwater flow, af ter a one minute time delay, shall automatically open the reactor i vent valves (described in Section IV) to relieve reactor pres-j-
sure to the suppression chamber.
- The operator shall maintain the condensate and feedwater systems ,
in operation so as to provide high pressure core flooding.
The above operations shall result in the introduction of teater into the reactor vessel to recover the core with trater if it
'has been uncovered due to a primary system rupture within the dry well. These systems chall rec.ain in operation until the level of water in the dry trell rises to the icvel of the dry voll vent pipes. This condition chall be annunciated by dupli-cate level alarms. The operator shall manually chut down the core
. 3 flooding systems at that tinc.
In addition to post incidest doeny heat removal by the core spray cystem suppression pool cocter, the reactor cleanup system non- .
regenerative heat exchanger nien shall be used :o remove. decay heat. Tie operator chall arrange the remotely operable valves in this cyctem for post J.ncident heat removal operation and escrt t'le. reactor cleanup pucp. The cicanup pump shall be rated at 70 cpn at 150 pelg dice'tt.rge pressure. '"ho cicanup system non-regenerati"e heat c::chagor chall he supplied tiith cool-ing water from the closed cooling water system. The heat c:: changer shall be rated at 2.625,000 Btu /hr for 215'F reactor -
t.'acer under post incident t est removal cperatiing conditionc.
. '"'to cleanup and cloced cooling trater pumps chall be pottered from
- the normal 480 volt a-c eye".en but arranged co that they may be stritched to t! nit Mc. 2 480 volt a-c bucca if required.
- 4. Refuelina Building - The refueling building shall be a rainforced .
concrete structure located it mediately 'above the reactor caiscon. ,
T'to spent fuci pool, the noti fuel ctorage facilities, and miscel-laneous auxiliary equipment shall be located within the refueling ,
ht'ilding. The building shall be designed for an in-leahnge rato not
- .o exceed 100'7. of its volume pc : day tihen the building is at a nega-
- - tive precouro of 1/4 inch of unter. Design epocLfications for the ,
refueling building shall be as given below:
(
O G
e .
III-6 g Building volume, tu ft 192,000 4
Minimum exterior wall thickness, inches 12
' Design maximum in-leakage rate, cfm at a * '
negati,ve pressure of 1/4 inch of wate 134 , 1 Personnel and equipment entry and ventilacion system penetrations in the refueling boilding shall be as given in Table 111-3. All other penetrations leading to th; outside shall be sealed.
- 5. Refuelina Buildina Ventilation System - The refueling building ventila-tion system shall have four possible modes of operation, as tabulated
! belows i-
- Building Gas Ventilation Treatment , Dry Well Mode of ,0f racion Air System
- System
- Purge Svstem*
(1) Normal Opera:, ion on 'Off On (2) Re fueling On On On
,(3) Building Above On Starts No change in Normal Raaiation valve positions 4 .
or fan operation
, (4) Building Isolation Off Starts Off
- These systems, which shall be designed to go into the " Building
.' Isolation" mode of operation on loss of control system power or
- air, are described in Section VIII. .
The change from one mode to another may be made manually by operating the master ventilation switch in the control room. Ordinarily, this switch shall be in Mode (1). " Normal. Operation" during power operation and in Mode (2), " Refueling", during refueling operation. 'If either area radiation monitor in the refueling building exceeds a reading of 15 er/hr or either area' radiation monitor in the caisson access shaf t reaches a reading 15 mr/hr above background, the ventilation system's mode of operation shall auto-matica11p change to Mode (3), " Building Above Normal Radiation". If any of the' four refueling building isolation monitors reaches a reading of 100 mr/hr above background, the ventilation system's mode of operation shall automatically change to Mode (4), " Building Isolation". These automatic operations shall override the master ventilation switch. The monitoring systems which initiate these changes are described in Section VII.
, In Mode (4) " Building Isolation", tha refueling building evacuation horns shall be automatically soundad. The gai trtatrent system shall be I
the only ventilation system discharging air from the building during this mode of operation.
- I
111-11 -
w .
i
- b. Low Pressure Cere Fleedinc System - Power operation shall be per-
' it.1ttee to cent 1nue curing periods when one of the three plant fire protection system pumps is unavailable because of maintenance. Each of the pumps shall be operated on recirculation at least onct each a m: nth during periods of power operation. The autceatic initiation of the system s, hall be functionally tested during each regularly scheduled refueling' outage. .
One cf the plan: fire p;ctection systa= pe=ps =ay be te.-pot'arily -
removed because of =41 :enance at any :i=a during cpera:1on, provided that bcth co a s;;ay pu=ps are operable, excep: : hat :he dies el- 1 povered fire pu=p =ust be cperable wher.sve: :he e=argency propane-pcvared genera:c: is :equired :o, he operable (:sfer to Section' W.-l . 7. a. )
- c. Reacter Ve.: Valves - The :eactor vent valves sb.11 be func:ionally.
tested during e4ch regularly scheduled :sfuelist outage.
- 8. Refu ding Zuildi.t Testing - Th*s :sfueling building shall be tested to de=enstra:e that the at: in-leakete ra:e is less than 134 df= vhen the building is under a nesstive pressu e of at leas: k inch of water.
Testics shall be perfor=ed during refueling er pcver opera; ten at the .
fc11cving ti=es: (a) prior to :emoval of the reae:c: head !clieving' peve:
., ,cperation, (b) 'af ter any opening cf the rail cad deer, and (c) afte: =at:-
te=ance which =ay have af fec:ed any of the refueli:s build.:t penetration closu:e seals. If no: required fe these reasons, the tas: a?.all be per- *
( .for=ed s: least c ce each =enth.
- 9. Refuelint 3u11 dine Ventila:1en Svsta= - A fune:1c:a1 tes: cf the aute=atic epara:ica of the refueling building ventila:1cs.systa= as"d'escribed in A-5 af this Sec:1ca ,III **
shall be, cenducted pric: to aach :egularly scheduled ,
- sfueling cutage ,
. 10. Centain=en: Receire ents - The 'following deff=1:1er.s shall apply ts con-tai:=e=: :eguire= ants: -
- i. :
a.. Reacto Svsta= centaie=ent "he conditica e=1 sting whe= tha reacto:
vessel and associated systa=s are closed so u to provide contai==es:
- of 1::adia:ed fuel vi:hi: the :tacto: core. ..
- b. ? ersure Suesressien Cen: sin =ent - The ' condition e.xisti:s when all drf vell and su;p;ess:.cc enar. c: penetra:1ess are in the pest:1er.s listed i:
Tab *.es I ':-1 and 111-2. Cperati:s 11=its and :egui:e=e::s fe' p;easure sup;;essi:n cen:ai :ent are :ha: (1) the =Ar te; van:114: ten con::c1 sv1.::h .c :.41*.y shal*. be s e: in :he "!te: :al 0; era:ics" ; cst:1:n, (1) the sup;;easi:n cel va:e: level shall be 1: :he : ante cf M.o :o 19.0 fee: (5.0 ::.*.1 fee: van: pt;e sut=e:gence)3 0) :heU.', rupp:n.ssi:n pee; e.=pe a:u;e
- ul's va:e: :e= ara:::e s..zi'. te les: :..a: 9: T a:d, :he
- f :..a g a s e . ::: n; :. e i:/ '.e * *. ::c '.e:(s '; s .a *_*. ':e it:s than 1*! 'T.
t .
,-lm N lV
- l. ( b)-U (. i b G " ' - { 7 ji '
y _ - - - - - -_
,k .
4* -
111-12
- c. Refuelina Building Containment - The condition existing when all refueling building personnel and equipment entry penetrationssare closed and it can be demonttrated that the building air in-leakage
' meets the requirement given in Paragraph B 3 of thisSection III.
, When only refueling building containment is in effect, the master
, ventilation control switch normally shall be set in the
" Refueling" .
position. ;
The containment requirements for the various modes of operation shall be as follows: .
- s. Power Operation - Reactor system containment and pressure suppres-sion containment shall be in effect at all times during power operation. The gaseous mixture in the dry well and suppression chamber gas space shall be maintained at less than 57, oxygen by
. volume during power operation. Refueling building containment shall
. normally be in ef fect but may be broken for the minimum time required to move fuel and other material in and out of the building, provided (1) Refueling building containment can be restored within ten' minutes.
(2) No movement of irradiated fuel assemblies in or around the
. spent fuel storage pit is taking place. Movement of ir-radiated fuel assemblies loaded in the fuel shipment cask ;
( .
is specifically excepted. l (3) No work is being done which could result in damage.to ir- ,
radiated fuel within the spent fuel pool or to pressure '
suppression containment. .
- b. Refueling Operation - Refueling building containment shall be in effect during refueling operation at all times except for p'eriods when reactor system containment and pressure suppression containment are in effect. At such times, power operation containment require-ments with respect to refuelirs building containment shall be in effect. ,
- c. Cold shutdown - There shall be no specific iequirements for reactor containment when the linic is in the cold shutdown condition except when the following situations exist. At such times, refueling build-ing containment shall be in effect -
(1) Movement of irradiated fuel in or around the reactor vessel or
~
spent fuel is taking place. Movement of irradiated fuel assemblies loaded in the fuel shipment cask is specifically excepted.
, (2) Work is being done which could result in d,amage to irradiated fuel within the spent fuel pool or reactor vessel. '
(
l During periods when refueling building containment is not in ef fect, s'ppropiiste procedural. controls shall be employed to assure that irradiated fuel movements do not take place. -
4
V t7
. -v=c l'
a
, , /udl 4mer +
1 . M ** M ! =
UWinni! .80U.
<r-c- . .,,,, D x W' h<-4 r e AN Nxx , N I
t :
s 1, v , @@@ N, ,<,our mas,,,aw c, ri,-o -arr r
" sv ,/ -
M // \ ( .
s
,, PN // \
~
~ ,,
ky // , , su.. .. rg ,, --
.s y ll ~ ~ .,
u.-1.r m, ,o -
('
m ,,. 2 '@ I ~b I" } & k CW ",
i er G 3) a
- y m
(1 (@
1 2 sss 1 1, y ,,
,, M \ \
I o-, \" \% =, - m. ~
c ..,, o .
- - - M NN , !
m_ s s.u
'g.
,_, _i i a Xs
.,ar.~ .,na, gg%@ @-
- > 1.
/
N. I s s apid';' i I ca << s. w p ..
I g m s. ara ,
,, se n ,, ,, s. ,, so na ., a ., e .I1 n A p < 9 4 !, ,
- c. - < .. ,,,,,-
1 $
OPEMTING CORE CONFIGURATION FIGURE V-1 i
l
r V-IS
. -V t p
(
-; b
~ t s ! s .
f: s .
3 a TOl_,. >
- b* -
t b " "
._ i __
- . i . .
\
, p,-_-e-__ _
%-. _ .= c e u
. , . p 3
, a
=
1 Il
.ga,
- 52
- 1 y, - -
a
\(
n , .
I n..--' -
!I I
g s
l
,ea-
-=,= rPG
[tl
!r.
i
, g
. I a s -
g I ..*
s
) .
- H 4bO ,lM k' A. Qn) L4_. U L Aj E !' I / a
'l (,* b g C
y _- e - _ m. 3
. % - == = -
- 1. .
- t i j,,
Q; .,
u y
e k
L, m
( w -
l- .
f
~~ " '
2 -- N,
.b1 ! (Q c 3 .
l l
- ' ,f
' % i Y'nj b*.%8{ggd% ' ',
{ (f,6 1
_ &&k.&
,t _s' -
(L _a
.. e y ..
TYtt 11 FVtt AllDL8LT FICJE V.3 -
" '. t .y *: . , : n: '
Cf.m3.e f 2 g-4=H- V-19 y W; l.Y .
l l n.. o 5 -
(Rev. 6-13-69) e !
L Is.. ,, .
, w ..<a. .
E *
' ,i ' . j . .'a . * ( ., . . . ! ' .t '
2 h . ,.
N es '
) .
S
?
.s
.'. = .. .. .
.. * , , ' d.
a . .
7 v ,
5 > *. . * * " , h
'. .l. , 5 e
l
, l . * '
i l . ; l' ' ' *:
o, ,
l
,..I..,;,
. . f. , W e ', ..-
+ - - 0 - . ' ,' , 'h . . * ;f., -
. .. '.....
- b s ,
D '
- . * .\ g.
t; l .; n, 1, . 1
~ - - ; . , .
.. i
.. ,,,., . - m ,. . 4 ..- ..,,. .
y g(
g ( '
li l
. , .y..i.,...
, .; p <. .: ; . ',.:., l.':
n a u, , '.'. ::.s'.
- w .i .l .
U.-
.y ' y .. ....; I .. .. . ,. .
. = = ====
. . : .': . v-
., 3.. . ;; : . ,
- u. w. . ; c . : . :... . . :u. .y .
'c o m' a - '. .;
r . '. .
. . t<.. .'~,.t
- a. u. : .
.,. . y ,:. . .. . ..... g. .
'. ] v. 4.:. . . . . n.
. .., n.. ..nv -..6.;,,
. . .e.c. . .
- s. . ~. ..
.. ' Q.
==
'.v y.. q : . .
'@$iCRQ(g@ 1i '=
- 900000:
g ,
.. j,F t : i 00080 d -
4;. )
o l,*, ,,
g E a a ,v.g -
- . 1 . ,;. ' '
OOw 3 \ .
u w' i' E 1.C.@.O.o,
- 4. . . . .. .
19^0-- .
gg
> $ 1 s..i ., .. s.,.
.g
\
g
- :: ,,,: m = ,= , ,,
.. ,. .t- . .
.s .. ,.
1E Y.,. .. ..
- . ', { :f.,\ . . g 3 )>' '..'7..
h . ,.'
w.
'.i.
. ' ( '.
- .,*.*i>. . '
[E
. _.* t ' ;f o > .
s 1)*m'o'o' P' f= ' '
'\ . . .: .,.) !
L a . I.* i. j
. . w. o. o.,e .e , ,
,i
'i L -= ._h .
=== .
? I Fa . ; i., ,
't -
g j N b.hufu MI-lu.
4,,
' n e ir l I # l
'i
. p N. , w.
s i,
. W .
i.
kg ,, l I w
l'" ..
w% ._
4 , ,p .
i.
1 i
. / t JJ anu s J -
f )
f nR 1 p
.y
(
agj bl. Jg ,%
m a i
- i g -
s o .
I.- -
h $ 09 9
, y g#cs9o9 ss fl
,1 .
- N - ; :
7 D 2 ' l g d , ; .
j
,~ t , ..
g w
. I-g . = <
= g
. I ~ sa~ a~ a.t: .; -f,._,....j.........<
. 3-- , ;
t::
fr%T@
i 2o Ay ? ;2 e- - .I, g Y1m i I >
3e-,e~g U U '
t 9
5 7 'Ti
- 1 B l pl AttI_a a v s ,
l* ,
!-~a*** I tlT T I l $ ! !
su u e.
u =n l 989686 / $ 58I I 880GO8 808@OG q'
- 'i i
s.Efg!
c pc :
GOOOOO +
I q__ r- E *!
868088 i yT:l l lhj !: '
@G86884 dJ U [
- -l
- 1. '
, [
e r e.
i mafc~iL.
y ' rp O h +i i ,
) s s ..
yt Tj)
. ( . i. ,,
. ., g/, c
-l e( ..rm~.
, ot...
,. wo . ,
~ (U o .. o ,;, %
n e
~-
( O;, o ,. * . > - --
h,4+ i D- .
e$
9j- i
f V11-1 .
t MONITORING SYSTEMS A. DEgICH FEATtfRES The gases from the air ejector e
- 1. Air gioetor Of f-Can Hwitorine System discharge shall be menitored by two separate gamma monitoring systems using ion chamber detc. tors which shall be designed to detect the noble gas fission products- indicative of fuel cladding failures. One' of these ;
t monitoring systems chall be an operating spare. The sampling system i . shall be designed to hold up the gas sample to allow time for the decay j' i of nitrogen-16 and other short lived activities. The off-gas monitoring l' channels shall be calibrated so that their indicated and recorded out-put cari be evaluated in terms of microcuries of noble gas and gase6us >
i activation products per unit volume of of f gas. Off-gas flow shall be ,
- monitored by a flow f ndicator in the control room. The information fros
- - the radiation recorders and the flow indicator shall permit evaluation j of noble gas and gaseous activation products release rates in the range !
, of.10-4 to 10 curies per second.
- 2. Stack Ces Monitorint Siistem - The stack gas monitoring system shall con-
- sist of two sampling streams with equipment as described below. The halogen and particulate sample stream shall have a particulate, filter, a charcoal filter for iodine sampling, and a sample pumping system.
Filters may be removed for laboratory counting. The gamma monitoring
' sample stream shall nava a particulate filter, a sample pumping system, '
" and two separate samma monitoring systems employing scintillation de-
- tectors. One of these monitoring systems shall be an operating spare.
( The stack saa gamma monitoring system shall be calibrated so its output can be evaluated in terms of microcuries of noble gas and gaseous activa-
- tion products per unit volume of stack gas. Stack gas flow shall be indicated in the control room. The information from the radiation re-corders and the flow indicator shall permit evaluation of noble gas and gaseous activation product stack release rates in the range of 10-4 to 10 curies per second. .
smergency condenser Vant Monitors The normally non radioactive steam 3.
which is dischargel'itirectly to the environs when the emergency conden-ser is activated shall be monitored by means of two gamma sensitive ,
These channels employing halogen quenched GM tubes as sensing elements.
channels shall have a range of 0.01 to 100 mr/hr. One of the channels ,
shall be a part of the area monitoring system which is described below.
The other channel shall provide local indication. Both channels shall be provided with an .starm to warn the operator of the release of > radio-activity in ,the event a gross leak should occur in the emergency con '
denser ccils. Also, the emergency condenser shall be provided with a temperature alarm to warn the operator of a coil leak during the periods of normal operation when the emergency condenser is not in service.
- 4. 1.iquid Waste System Vent Monitor _ - A fixe.d gamma monitor employing a halogen quenched CM tube as the sensor shall be installed on a vent header which collects all vents from the tradwaste facility. This mon 1}or shall have a range oi 0.01 to 100 mr/hr and its output shall be recorde,d I- in the control room. It shall be provided with an alarm which shall leo annunciated in the sentrol room.
g . '
c t -
, \
- V11-2 >
, 3. Process Water Monttors - A process water radiation monitoring system i employing scintillation detectors as sensors shall be provided to in- ,,
disate, record, and annunciate high radiation level in the folfowing i prosess linest i r
, . s. Condensate to condensat'e domineraliser. - '
j
- h. Closed st,oling water return to storage tank. {
j s. Reactor water to clean up dominera11aer. : !
t 7
The above three monitoring channels shall be used to provide a quali-
, tative indication of process water activity. !
i
- d. Radweste discharge to circulating water (Esch batch of redweste :
shall be analysed pirior to discharge as described in Section VIII. !
This monitor shall provide an additional means of checking the activity of the wastes).
- 6. Reduelina guildina Isolation Monitors - pixed gamma monitors employing 4
ha:, ogen gutached GM tubes as sensors and with a range of 0.01 er/hr to ,
10 r/hr shall be installed at the following locations within the refuel- l ing building: .
- s. Refueling building - South wall access door.
f
'.I
- b. Refueltag building - Northwest assess door. !
i
- s. Access shaf t-bottom.
- d. Access shaft-entranse. .
A high radiation signal from any one of these channels shall, provide a !
t "guilding Isolation" signal to khe refueling building ventilation system '
and shall sound the refueling building evacuation horns as described in Section III. The output of each monitor shall be indicated and recorded r in the sentrol row. Each monitoring channel shall have its own power supply to increase reliability. ,
i
- 7. Area and portable Monitorina Reuipment - Thirteen fixed gamma monitors ,
I employing halogen quenched GM tubes as sensors and with ranges of 0.01 !
to 100 ar/hr or 0.01 mr/hr to 10 r/hr shall be installed at various lo- ~
i cations throughout the Unit. The outputs of these monitors shall be :
.- recorded in the control room. Each channat shall have an adjustable high .
radiation alarm which is annunciated. .
One area monitor shall be located in each of the four areas monitored by i
- the refueling building isolation monitors. A high radiation signal from i
, any one of these channels shall provide a "guilding Above Normal Radiation" !
4 signal to 'the refueling building ventilation systeur as described in Sec- ;
I( tien III. The two area monitoring channels in the refueling building shall j f;
_ . . _ - - _-.,-..[.,.,..,_.._..-__,-,_,..._.-_,,____,_,_____.--_____.-________,..-
VII-3
( also provide gamma monitoring of the fuel storage areas. A high radiation level signal from either of these channels shall sound the evacuetion horns in the refueling building.
In addition to,the area monitoring system, suitable portabJe alpha and ,
beta-gama detection instruments and beta-gamma and neutron dose rate .
instruments shall be provided for use of personnel entering the Unit's radiation areas and radioactive materials areas.
- 8. Off-site Environmental Monitoring Stations - At least thirty off site environmental monitoring stations shall be provided for determining the integrated gansna dose rate in the environs. Each monitoring station i shall be ' equipped with two 10 mr stray radiation chambers and with a film pack.
I i ,
- 3. OPERATING LIMITS AND REQUIREMENTS ,
I
- 1. Air Ejector Off-Cas Monitors - At least one of the two air ejector t.ff-i gas monitoring systems shall be operable and capable of initiating '
closure of the of f-gas isolation valve whenever there is off gas flow during power operation. The conitors shall be set to alarm if the off-gas activity reaches a level that would correspond to a stack release rate of 0.01 curies per second and to initiate closure of the off gas isolation valve if the activity reaches a level that would correspond to a stack release rate of 0.5 curies per second and remain at this value
' (or higher) for 10 minutes. The calibration of these monitors shall be checked at'least once each month during power operation. The automatic functions of these monitors shall be checked at least once each quarter during power operation.
,, 2. Stack Cas Monitoring System - At least one of the two stack gas gama monitoring systems shall be operable and capable of initiating the stack gas high radiation level alarm during power and refueling operation. The monitors shall be set.to alarm when the noble gas and gaseous activation product release rate reaches 0.05 curies per second. The calibration of these monitors shall be checked at least once each month.
- 3. Emergency Condenser Vent Monitors - At least one of the emergency conden-ser vent monitors shall be operable and in service during power operation.
The monitors shall be set to alarm at 10 mr/hr above background. The calibration of these monitors shall be checked at least once each quarter and the monitors shall be source checked at least onco each week during power operation.
- 4. Liquid Waste System Vent Monitor - The liquid wasto system vent monitor shall normally be in service and shall be set to alarm at'10 mr/hr above background. It may be taken out of service for maintenance purposes but shall be leturned to service as soon as practicable. The liquid waste ,
- system vent shall be monitored routinely using portable instruments when
' the vent monitor is out of service. The calibration of the vent r.cnftor shall be checked at least once each quarter and the monitor shall be source g checked at least once each week. .
8 e
o 4
V11-4
- 5. Refuelina Building Isolation Monitors - At least one of the isolation -
monitors in the refueling building and one in the caisson access shaf t shall be operable and in service ,at all times durina power and
' refueling operation. These channels shall be set to initiate a change in refueling building ventilation to the " Building Isolation" pode of operation and sound the evacuapion horns in.the refueling ;
building at 100 mr/hr above background. The calibration of these monitors shall be checked at least once each' quarter and the e
monitors shall be source checked at least once each week. The automatic function of these monitors shall be checked at least once each month as part of the refueling building testing described in 111-B.8.
- 6. Area Monitors and Portable Monitorina Equipment - The area monitors normally shall be in service at all times. They may be taken out of
' service for maintenance purposes but shall be returned to service as soon as practicable.
The four area monitors connected to,'the refueling building ver Ui-tion system shall be set to initiate a change to the " Building M+ve Normal Radiation" mode of operation as follows:
- a. Refuelina Buildina Monitors - 15 mr/hr. At least one of these channels normally shall be available to monitor fuel storage -
i ', areas and sound the evacuation horns in the refueling building.
If this condition cannot be met, monitoring shall be accomplished with portable instruments whenever personnel are in the refueling building. .
- b. Caisson Access _Shaf t Monitors - 15 ar/hr above background.
- The remainder of the area monitors shall be set to alarm either at 1 mr/hr or at.a radiation level within a factor of two of the normal maximum indicated radiation level. The calibration of area monitors
. shall be checked at least once each quarter and the monitors shall be source checked at least once each weck. '
Portable radiation protection instruments shall be calibrated .in -
accordance with established schedules. *
- 7. Of f-site Environmental Honitorina Scations - The stray radiation chambers shall be read at least once each 15 days. . If the results -
from any monitoring station indicate that.the total radiation dose above background would reach 500 mr in a one-year period, an investi-gation of,the cause of such increased readings shall be made, and the
- necessary corrective actions taken.
I .
(
f
'e O
0 b Wn l $
//[2 Da a/M1t2 AJ
,A An Ay-A d v .
m rs . /As Am f
/L ~As I a
& Am.
b o
. .N,N. y gpg
- gygacy _ ,v_y
- p. kasi - -ifl ( < d'Atolda's/<< .
r,S,,,,,,,,.y l , & s'ee/w <h,
( r; 3, w w, fr m p1,he 4):lber hdMSYendo
$s auchbsfe
- C,o v 41- + 3g v. 4 it'dputu6 .
/0/M/4/ 9 xxu{s da Yksfsno1 y 4 //gj' f
4
~1 g d d / a k .e l o d A Mee wdeig ad<yn6a/ /
[,
!" a r< d cp w (a) g i pioDe /oisaas b awi9 h' auda<+ , fuhady / bin 6, ale aAa# xA> fed dp>scaty teyp&&uy d> 66e //ewic ,_e ibwa.. f(9a/p+/D,1{lpy'he/ij e
~
'""'* O/") .a., k ,,
a e i
~ _. ..
g g e a e t .
- m,.....,,. . . r- . , , . . , . - - , ,,,,,,.m., ,
c.r_crr'. .... m j
, .m
- f. : n i
": 1 l 8 l 8 3 A L
,h, :
.o, >
4m m
,- m u :
}
(
r U - { 7 I
L
. gg g a L * & u .
m , m
. .E. a.
im s
- E, . ,
5 m.m
.o e
= y , ,
,. u .
le, .,
Lm
+ u .a l . . ;
5 4
4, o m I .M,
- 5. 22 l.o, Io
.m " . .
m' y 4" e y,
- r. 3.. .- ,. . - = ,
. . i
< e X o.
. 2 , ,.
E y . .,.
y
,. 5' 5
4
.- m
- 4m ,
m a .
.. -. 5 y ,
W-,1, L.
-t ,. . i, , , ,
m Ii
't
'- E m,
.s -g , .,
m g
,1 E != 5 ., .3 t
.ii y
e" ,.
o.
. .I .
,m . .
,. e m
. . . .E. . .. W 4 3 . m
- o. .s
- .E c,,o. -
o m, 2 , ,
m . 3 3,r ,, - . ,
.u. i L, o .- ,
mI, Im 3 ,
,f
. ,o y
" o . - ,. ,
, s , . .= t m
g k.g , . ,
r m,
- m ,L L
- W ;I 9 . -I X 2 1
- ::
,' x L ur y y ~ s om o ,
W ,
g .
m . m . m m m ,
. m m
,m ,
y e - - .m m , .
u J u- t u - g !
- g uiu p
- .
- o ,
m - m
- i. l ,
14 L!
{E,
, o
! ;g ;l
,, , , m
.. , g E u um , a, s u ,. . . . . . . .
g mg m ym o. . .
e m
e ; .,
rm ,. 8 1.t u o .,
o , , . . ,. , ,,
t u,
, y r
l i,: ,
g
.I
- m o.,
m ,
- .o o ,
t.
I. ,
ms o o
m m
.o ,
.m , .
g
,,g ,
a af , m c o , , ,
gy . .
, r , ,
,.g , ,
I.g. i mL..c.
m u
g
, ayg- o . ,= , ,
= = = = = = gr m
s.. u j u' s
~
u
,a = =
',gs"".o g :,
pom mo u ., m , ,
m ,
,, m m ,
- ,4 ;-
1 t ,
3 i
- t. eUu a
uu ug 1
g 1
1 g
i.
i o o o o o
-m. o. .o 1
t,. , , , , c . ,
- m , m . u ,. ,. - - - ,. .,. ,
'~
d j UE da j, f. I I I 2 I I ,
[
- ma a . . . . . . .. ,
g;g I g 1g g g it t i t i t t g.
g-
- - - - - ~
. < m - .
. m e o , ,- . . m ,
u- L e
s" e
. . ,.,., .,, . g.
I o m ,. ,
", .0I "uu Y ; 2 : :,4
.A A A A A gA I I I 4 4
, u, n u .a m
" 31 1
2
~
! ; i i i 8'
[*
t,a alh qu h l-I' W i, il i- , , ,
- i
" = , , , '
- m. ..
ll
, f 'I iI , ,
j
{
- l b ,
< es s I sE t aRaumaaasaaansaaeaamaha1&n1Rh E ad ela R E B E I AA I RAA EE 3A mat #
,( EE E RTIEEI ENY I EY E IE 1 5 *j s
} } g g g c <<~~w. *-.eey n --a s.. s , _ ., ,_ . , - _ ._
s n - = . . . n a n . .$-
1r E n a a a r s a a e s r a I r i i n a s = a r a*1 '
4 i 0 $ ?
9 0 i 0 0 e 8 S S
$8 4 0 0 e 4 4
. O e O e 1'3 0e 0 ee e
e e
0 e
e
. 0 0 e 6 6 0 0 0 e e e e e
e e e 6
l0eI
!4 e 8
e 8
6 0 e 4 ou e t 4 4 4 e is 0 0 0 0 0 0
- e. e 0 ans e
e e o ee e 0 g
e o e oe e e. 0 0 e
0 0 0 09 0 u ps 8 0 0 $ e 4 * -u e t #
4 0 4 0 0 9 0 0 e, pg 3 0 02, 0 0 0 0 9 9 e o 9 0 t oe 0 0 0 00 0 X o.e
. a e.e a je 0 0 6 se e 0 0 0$ 9 se > ha > es a > **
0 tad 0 9 0 0 e ene D me as bW u O l0t 4 0 0 $0 8 0 t.as
- m .,J a e o se . 4 ** ;
e 0 0 e4 6U e en. E > 2& ens O .6 4W G 0 0 4 e2 a k o me oe a tus t 82:
G 0 0 0 0 as e y > og 3 tas a= ,' 9 0 ens .
0 0 ene e 4 S S 0 0& =* .s > es Ons se p =a ,0 0ueo .
e ene 0 0 0 4 9W h ium o ha u as W ** 3e 3 't 0 0 *e 1
, e> 0 $ $ 0 0E O se ** A eB u E
> ja l *e E es 9 e th ena 0 **
- j u 9 0 8u e 3 gg g og a
' 6 > Ina e 4 6 8 0 se 3 o go m ens u se se > 't 0 ans >=
l $&J4 0 0 0 GM ON M ep .a ~u 2 2h > E $
0 Gu.
0 4 >
e se > j 6 6 8 4O mel
>E
.,8 en o.e a to t=
o tas O 2 e be O he
> 0 0 - et 0 m me v 8 4 4 0 3 3 e th 8*
eup6 8 0 8 e> as k en, ao se . seo as aa u ene i 8 ee2 8 80 4 0 0 t 9E pu O uE u >= to taa i I 't st 0 ena 0 4 0W e> 24 .gj gg g g3 4 se l 0 .N **O 4o e 4 0 0 0 and ens e es se a ans tas tas e ha D O as - 38 9 8 D=
$g 8 0 0 $E & 3 i 3 se 3 u u lE u .= ep
$ LS 18 e tas as e 0 0 e == a 0= , O OS e m.e.
ep 8 0l 0 4 0 6 0 en u* se a 0 e= su > a z ens 4 le e u ea.
GT 4 4 ee eo O tus em , s.e
,e a eg o ens ee >
,8 0 we 0* $ 0 00 8O O ro iu as 3 3m > > es se ,8 0 e e=
J 41 ls 0 f0 8 0= , ens W ene U .A 6 O, saa 4i t u 9 02 3 2 >* i a 64 m O O E tha Ina a a 0 0 0 0 0 0 0 ena las se tha 2 ans og g3 gme e6 3 3 O 9 0 ao et e tae ,
e, O
{w 4 0
9 0
0 0 *e 0>
- And
>a we O
> ,oy i, su as an a
a me 2
se ans a
se se as a
9 0
0 0 me s e 4 9 4 4 4 0 8 he tas ena '1 0 0 0 0 0 0m e a i
- 0 4
. 0 0 0 09 $ i f se 0 r 6 4 0 0 e e .
i 8 0 ens e e4 0 4 0 0 0 e 0 9
> 0 ea 0 0 0 0 0 6 8 4 w 0,4 0 0 0 0 0 g 0 t 0'O 9 0 0 0 8 g 4 9 e et 0 0 0 0 0 80 A 4
> a 82 0 0 0 0 6 m <a 00 0 0 0 0 0 4 0 0 9 0 0 9 0 ** 0 ** 4 0 0 em 0 0 0 le 9 6 km 0 0 8 6 ww eu e 0 8 0 0 et 8 9 a> e se 0 0 0 4 4 0 o
. e 0*
1 0 0 ee e
'.'0 e e e
e as E 0 O 9 't 0 0 s O e e 0 t
- 0 e r.ai n 0s e e l00 0 e 0e e e o e e o 0 0o 0 0 0 g 9 4 F e. Gna 0e 4 6 6
mwa 44 $ $ 0 0 to e e $
1 D e e O Op e. 0 0 0 , l
('a_weruoe O
e,m
. 8l.
ee 0
0 0
0 l ! O 8
0 8 0 0't 0 0 6 i 4 et 0 9 0 0 $
O, u. ,
l
- 0'.
Eo 0,006 0
9 0
0 .
0 0, ,
1 0
- e. > 0a 6 0 0 0 0 f e
it t as as 0 O e- 0 0 0 $ e I
- = a 0 .A a 0 0 0 0 0 0 0 # l 0
3 0 $=
0a00 8 Q em 0 4 0 0 8 u
{ 8 8
3 0
8 0
() 0kW9 0 0 9 0 $ l 8
0 8
.A 6 as 0 0 0 0 $ e 4 0
e 0 0 0
0 9
t9 e 0 0
0 8 i v 8 0 0 ' 8 E, 0& $ $ 0 0 0 0 i 9 3 03EO O 9 9 9 a eE 3 0,a u 9 0 0 0 t 4g g g g r 3 1 ' O 4OE8 0 9 0 0 e '
t '.A =a 0 0 0 0 0E E E e l 8
0 01.A e 0 0 0 0 9 0 I 9 0De0 0 0 0 0 0 0 0 0
) #
0h 9 0 0 I t
$ $ 0 0 $ 6 0 1 0 0 0 0 0 0 0 e 8 9 0 0 0 4 0 g 0
9 0 0 0 0 0m e's a 0 1
& ' 8 0 0 0 0 0 0 56 e6 0 i 8 8 6 0 0 0 03 3 3 g 0
0 9 0 0 $ $3 a E g I
0 0 0 0 0 0 00 0 0 0 0
$ tv 0 4 0 s .A .a 0 8 I e 0 9 d 00 .A .A 8 0 las ene taa he ene the en8 u 6 0 ml 0 0 0 0 00 0 0 0W u u u u u 9 e6 0 $ 9 4 4 th th eb 6e m m s >e ** ** O s;> 0 0 0 0 6w w w 0 e.e e.e e.e o.e > > > f e
4 0 0 0 o, .
O. 's= . 0. > > > e, o, o, O, O, O. O.
0 9 . 9 . 4.
.. . O O O 0,.
. .n 0 . . . . 0=
. . .8,O. O. . . O.
. l. .
0 0
0 0 . .
On n s 0 O., .,. a - - - $>
" ~ ~ ~ ~
l
.4 .-
- ~
0
~ ~ !
i
.I 1
S e.n
,.,e
.* ~
~ 0-0.,
.- 9 .
9 .
0 0- - 6
.. . . 0 0 00 t
. . ,a . 0 9 . .. ~. . 9
,.,, et - e - 0-0-
t . 9 . 90 . 9 . . a 80 et 4 . !. . 8 0 .
9 e. ,. e. ,. .
=
. . 0 .. , ,. , , = =
~ ~ ~
- . !. !. !A Se A
e 4 t~
0
~ ~ ~
l.'
(- .I e 0
0 0 0 0 0 0
0 0
9 0-0-
I .e 9 0 0 0 0 w
.. 4 .- e .-
ou 8 0 t..
. 0-0 .- 8 .so e
~.
80 O
m o
m t
0 0 0
. 0 0
8.
0 3 .
. . o 0 . . .
- 7IEE'IRAEAB R aaE aaaiaat aaeaaa33aaaa1 aaa1Ah ' I E I E E : A 4.I J E 2 I 1 E E I E E EEIIEAEE INIEEY E IAEA1 0 9 0 S 7
- - 3 i 4 8
. n . . ,
e ^ -^ . . o 8' E e. ;O p .E O
- 8_2 / 3't / 8_4
. - __ _____. .- _ _ _ . . - - ._ ._ ~ ~ ~ ' - ~ ~ ~ ~ - - " ~ ' - - -
_. DUT8TahDING ITEM 8 mEPenf - - U
=
Num80LDT SAY PCSE OPEN OPERAT!048 ITEMS . ,
m
. a l= . ......... .. 1. ... . .... .. ... ......... ............ ...... ...................... ... .. ............... ,
DOCKET ITEM.NOW~' TYPE FOLLOWUF~ FOLL0mUP ~ 8T&TUS 'ACTIOtf BATE DESCRIPTIVE - .
=
SashCM REP 0af wo. TITLE = . a
. .... ... ... . ......... .......................&.. .................. ..i.D .M i.K4................ ........ ,
,, - a
~
.======= ... .. ..................... .. .......... ............ ...... .... .......... ,, o a
i.
. .... ..................................... .. .............. ............................. ............ ....... .... ,, g l 58133 TI.15 26 TEMP INSTR (TI) 8 8 A0m!N CONTROL 04 DEFEAT OF 848 .
DURING CDNTATMMENT PUWEins .
. e
- - TI.15 29 Temp INSTR (TI3 8 8 the*ECTIOis attuteEnENTS Fee .
I C EULT,t14= 15.Ie .
" o
. 71 15 37 TEMP INST 4 (TI) 8 8 INSPECT RESUIREnthTS FOR ,
If5 88.!T-(NA80N#r SLUCm . I MALLS) . ,
. 71 15 39 TEMP INSTS-(TI) 8 8 IntPECT ASNTS FOR IES 88 17
. - t 11 15 46 TEMP INSTR (TI) 8 e'
8 ADEGUATE P80CEDU4E8 TO '
- supt sa m ATNE
. . e
'. Ei . i ,
e W N
= . ,
W w
.. .e . ."
m E 9 L
be
,, - e s e f .
. u en m
6 9
O
~ * ^
.......... . . .. ..~ .
t i
. . g
. i : l l ..I
- [.
- .
.:?- :
I
- : : t
- : j '! :: ll Y
':: jeg .: '
i I tr l :
I t:s
- :=g
.s rc
.r
- n-
- 3 :: l: :l: ::. c
- 508 . ..: igrE:-
l
- x* :g:g l:. :g g ai,
' " . g"
- l. : " *
"3
- : : si :3- s 1.~1
- : !! ! lO:20 .
I :
lll 8r8721
- "~2" 5 :. : : :: !
0 :: : : ,t:
l
'. 1." : it g
[:A
- 5 : :
': : ll r: != l. : : :: :
or :I l l: :
'" -= :" ' .s. . : Imll. !.
- i
- ll: l (a"*S T: 'lla : : :
- .snl :l rl:
ll -
lu*: 2 id5l : ijj l
,% l22. ig g l.
tS li " : '. .
i: l :: l 6 l'.'?"l : ::
=
ist.: : :: l 1. .
- e:: : :
- :- : : : :: l i :. :. .: : . .
.g .
l : : *: :
l' :.
i..t . . g
- . :: g j..7 l l 'll .
- : . I ,L : Y
!; l l "l; lE E lL : au :
l;5 ! ! :W :: :
's4 i l li i
i i-m m .o .a
( ul I .* i::
i' L I 'O= '
3l 3 I ll L
' 1 l; ".
l;
- 8 m j .m m .
.4.
- l' *ll ll*
. o . : o o 7u..........................,.....................>... ...>.....i......... >
0 ; e e e o e e e e e e e o e e e e e e e e
!. II. I"o m
o . 3 o m, . o
- t. .
- ..o
. l.
g o t . o. .
M . .
1 1! j 0 t o ;!. .! .
o o . .
o o . .
- l( "
8 ..S ! tr 2 E. .
.o ,
.. s f 3 l
.o 8 ... ! . ~
.t . . .
. d
. f a
.K. . .
8.3 . - E - - -
8 o, .
o
.I .
3 .
= .E
.s
- o. .
w r..
.E.
~ .s 8 : 8
. & . o. t
. . , 2 .
, .X .. .t .
5 .
s o.
s i t ,E o .o d ,- i o
1 .
.a a .a.
. u . ... .o u . E o -
s .
- a t-I ll I. 1.8 to. = W t ,t
- . s . "H. T N
, . W .
.2 .
. - . . 2,. .
.t
.s o - . . - ,b a
a 14 l.
j ,g
.o . u s
. .s -
o
, g g ig g . .a a. a
, . o o ...
. 8 o o .
l o o o
o o
= o E5 .!
o o o .
.- 8 .
w u
.. .t ... !. I.
.I
.t s .-
s ! = ..o . .. .
o- .
-. .. , . -.t o . . . . . .
o
- o. .
.. 8.
c I a .t
. . h a, !.! .
t.
i .. . . . . . . . . - . . .
- . s. .. . .. ..
g gggg g ;g ;- - - - - - - , - - -
, a h. . .
s o S
! I.
- t. a, r . ..
i f a
ov . . ,. .
- l. .d..
s
\,.t .
i
. . .. o
.. o .a. 2 a a 2
a 2
- a. =. a. t. .a =
.. o
- . o . a.
.. a a a a a a
. . . s a a a a s a s a t ! ! 4 td d d d d d d d d d it:
- t. - ...l.
1..l
. It t t t
t
~
a t
e a t .
g :. . .- . .
g.
,. ;g g
. 8 ... . l~. -
- e. ..
o tv t.
!lt.. .l
.5 .
IC . .i..
.I !, t. 4' t o
o
. !.. l. .,
M [ W* lt! l' t- -
! .!!. I. I. !"
nn rrrr i . , . . . .
. . . . . . . . . . . . . . . u . . . . . . . . i . . . . < . .' . ' . . . . . . .
e e
.O e e e e s t . ,,: a .e . . - .: a - . . - - =
u .
l
.' :. .l
- l. ..
I ll : :: :
C
- 3. li W
- l:
) 'l : : : :
- (. '
! ! u! .
l ':
ll:
o .
l : :* : W: : 1:
- :l
- .r E -
.tr i :
i.
- ::ss.2
.--a, l
- . . .3 . :
!. i: ! ... "~ f f I* F. I
- e:
- ,: rg 1:::
ix-: :
i
- : : l':' .u- -=
il!
- :. :. l.'. . :! :h.
i
. "* . .L". .= .
l.
. g g ..-os ,
i
- l. l ,-ll
.M.i.t.ata.
o .
- o ....s..
. i. ,
, . m m . .
- g ,u -
..o
.. u.n, :
- :: a i :: l
.. u t :t 28 l5 u :. ti l.
o .. o I0 :
t I..
S. :. . .
.r :! : . I :
- t" 13 j i i I
.6:5 ; *; , i. l'ls l.:. 1. . !
.g e m .
( 92 t," ll : i::
c' . '
O.'
lgo. ."3 :
-- . a n. .
.s . . .
a" id2: 1 !. :
- . 1: :
s s. l' II t i:g 2 [.
.?*! l 8
- = :31: : '[:.
.l I.
!.d::. :.
- 8 :.l [.
l.. '
l i. o lll l' g
- ' IW I :'
- l I:
- '8: :
i l : :: :s s
'l-
- . I
- i. o in :.
' "r. =. .
- 1 .
- i. , .
., !. ~ ~ ,
i i
l'
. r ,E "3.ll m e fl o
'O.
1 -
.' , ud.
?, m u
m -
m.
?, ll
- ll " "
c .. . . .
N "
h "-
. p (k
$ l 3' "X "a
- l
" I
, =
,%. u u n o l"ll o o s
L.....................................................................-
m .. . . . , o 'o o , , , , , , , . 2 2 2 e
~
t
.. '.9 W. 6
- e. . . .
- g . . .
i... ..
- l. I .
D.
8 t. - - , ,
t .. . . . .a. . . o . .
. f .
.. s
, o, ,
o .
. .. .,; 2 . ,
. .u - > - . .
= .
,.. ..so t! o.
=
- o
.E.5 .
o
. .#.. u
= .u o
... ....s
. ~u,s .
3 .. ., .a .n -o --o
..s .
. ... .. s o
- f. .r* >=
2
- o,2,os .a
.M-.... ... .. ..
.... .= Y.
.s. .s.
,- . .=.
.. .x .
5.. 6. 5.s. o W .= t' .,a.t E , , .
. .-E j .. . . ,. .
.-6 o .s u.
.o -
- ..a =# ..
o
. . s o
~,
! o,.. .. .o . .- . 2 = a .o,
- i. . . .. " -
8 .
S ,.
! t..,..n. u ~c o u. . .
+-
.Y
.o.
....so.
u
.a5-= - ....8
. ... ..En.
..oo..a . . . o. -.
~
., u.
. ...l.
- o. u .
o o
...o.x. - o..R. o,.
o a -
J. . .
. t t . .
m,, o . . .
. o-
,e o . .
.t , t.
.m - . . ,..
o.
~. .-
.o
,,..n: !. !. t
- l. ,1 8
.. I .
I.
,#.n I.E !. !. . . . . . . . . . . .
o-
~ . I.I i S .. .
a,o ..
(. . .
o,
..o.. r. .
8 .
i
. u. a .. . ... . I a.
t.o s... .
o t.,so..
o..
.. .. ..I .
..i s . . ., .. .. . I 4
o . . . . . I
.. . . . . . . i i ., .nr. . :. .
, o, .u
.o l .d.. . l... .
t.. .
i.... .
i i..
. t.
. .... . !. .! l .
i
. . . 1. . .
l
. w
. . .t.. .
i l l-
~
- l. t.. lt i.o.
s .d, d
u.
d o.
d o.
d o.
d o.
d o.
d
.u d
o.
d o.
d u.
I l,
. . . . t. .- - - -
o u
o u
o u u '
g go o u o u
- i;.
- 4. g. .. . . . . . . . . . . l
.l. . ~ .i. - -
g l, jl t
.t.
. m. . W. . . - - ~
.~.
.. . . ~ . . .
i .5 .. m m
..loo
, ! =. o :
. o, . ..
I 1
.o o
o u
o o
. . . i
.o. .u. .o g q,g ;
o g- .o. . o.
. - o.
, . . . . I
(
..- j . -
ow o.
Im .oo .!. m.o m m .,
l mo o o ,- , o ,
- m. o o
[
m o.
ll ll*
. k. o
. o t'o .
1- i ai>>>>>>>>>>>==> >>>>>>11 min. > >>: -
a . u u ais.u u s I u s i e'
4 0 e e * *
- e e e e o e e s a 6 s a
- 6
3 /
- _ _Oh _/.0. _6 /. .S_ . -.. .. - .*
ION 5
.. . . _ . . . . . . . . . _ _ . . . ._ 'A.st 4 ._
MUMSOLDT BAY PGRE 07EN OPERATIONS ITEKS bl[ W k
) :. ............... ....................................................................................................................
=
00CNET ITE4.NON-~ TYPE FOLLOWUP FOLLOWUP STATUS ACTION DATE~~-~"--- DESCRIPT!VE .
BRANCH REPORT NO. TITLE
() l .................................................................................................................................... ,.i
= .................................................................................................................................... ,
(3 : ,i
. .. . . ... . . . . . u. . . . . . .~. u. . . . . . . . . . . . . . . . . .M.'.WGGnu se . . . . . . . . . . . . ... .. ...;. .~GGG.EGGu u..;.. .e u.u u'u .. . .u u.... . . . u~.
~
c) ;
'() "- ....................................................................................................................................
0 FAILURE OF 120 VOLT VITAL AC 50133 IC.T9 02 IE CIRCULAR 0 a POWER 90PPLIE8~-~ .
C)
3C.T9 04 It CIRCULAR 0 0 LODBE LOCNING NUT ON LIMITOROUE
- VALVE OPERATORB .
IC.T9 05 IE CIRCULAR e o MOISTbME LEANAGE IN STRANDED .
- W1RI CONNECTORS I
C) .'
- IC=T9 80 IE CIRCUL AR 0 0 PIPEFITTINGS MANUFACTURED PROM ll
- UNACCEPTABEE MATERIAL
- c3 '!
I. IC.T9=13 IE CIRCULAR 0 0 REPLACEMENT OF DIESEL FIRE PUMP
- STARTIN8 CONTACTORs
() l
~
c.
IC.T9.lf IE Cl#CULAR 4 0 CONTACT PROBLEM IN 88 12
=
~
SWITCHES DN 5E~METIECEAD *
() l CIRCUIT BREANERO LOOSE IMPELLAR LOCNING DEVICES-
- ON TNSERSOLE~. RAND PUNP5 O
l IC.T9 30 IE CIRCULAR 4 0 FAILURE OF GTE $VLVANIA. RELAYS ,
a )
C) 3 IC.T9 33 IE CIRCULAR 0 0 STRONE TIMES FOR P0MER OPERATED i a RELIEF VALVES tPORVf5) !
C) : 0 SHOCK ARRESTOR STRUT ASSEMBLY IC.T9 35 IE CIRCULAR S
- INTERFERENCEi LATE 5Y~ EFFECTIVE ,
C) : Is sur A
.. IC.80-01 IE CIECULAR 0 0 SVC ADV!CE FOR GENERAL ELECTRIC ~
a INDUCTION DISC' RELAY 5' * ;
C) ~'
IC.80 02 It CIRCULAR 0 0 NUCLEAR POWER PLANT STAFF WORN
= NOURs C) ;
C)
O C) < - - - - - . . - . . - - .
b
-- ~ - - ~
i l
L .
. n.
9 e t 8 8
9 9 0 g e S 'S e S 9 0 0 S .
S S 9 9 8 8 '
8 0 3 5 9 .*
m 9 e p 9 4 S S +
, lp e e t S 8 -a.~~-- *
- w e S e s ee S .
0 0 9 5 .
'l I
et 9 9 9 6
-- g.
3, a 6 8 8 5 e ea S S
S S
S 8
E I 0 .
.D S . 3
( .O S .
S S e .- e e .
0 0 0 La E E 'E B D 0 8 he as as me 3 .
O 8 8 9 $ L i>=
=e.J ,
4 J B. b M -- l 9 0 0 0 0 e. i a S e ee S e S e s .e pe e
- e. L a as ne m z. me me 6 z ,e E .e - i e 93 6 E IB 4 us :E e 9 9 9 8 e IB E E P twe I 0 0 9 0 0 9 D= X e De
- i 8 8 9M E B 2 > IK 0 0 0 tUE J te A. De 3 2 'S me
- hei m g e as S 9 0 9 ** L M *e e e $= 9 6 9 8 9 De E e E >e SJ LS # 4<E ** .- I S ** O D G B 8 E Pe U SW P 3 l 8 9 SWE M > 4E S&WS 9 9 8 9 L- E E he SD .J > l e&Jj 9 9e > E U E hs O $J g e twea= w S S S G 3 ee >M 0 E >+ 0 0 S S SO J GJ 3 EW e aJ e= 0 8 8 9 9 as > 2 8
ans iK 8 S S 9e .J 43 O ' *
- G WD S S e me 4 h. ~ O
- 3 bas 3 3 S S 02 ts e B en. 'iD 2 ib 9 9 8 se - ha
- 0 0 8 9 E O Di3 '
s S 8 9 9 9M EB E e he S 3 0 0 5 0 e 4.3 E SE E ke > >= tb E S 9 84 > he W.
9 9 S 9 0 9E as L O O O J'IB CD e D D M U 4 ae 9 0 0 0 0 0U bd >=
S 9 9 8 6 > he h4 J' 'E EJ }
S 9 9 0 GB E DE ED e3 af G 8 8 es D 3 e5 M->= 3E (
S 9 9 0 8 as B
4 S S ma b= ML .4 3 tas e uM .a 2 l S 9 9 2 hs * * > => EJ me E pe i n. i 9 9 9 8 8 9 E IS Z 4 t D 8> 3 a4 '
8 8 0 e b . W U h S 9 9 0 8 9e k S 9 9 9 9 8 ~ *-d t, et S 4. }
tt S S S S S - g 9 A B ang S S 9 S S S S S -%," *
- t- S O 4 0 9 9 0 *
- e 8 S S 9 9 8 * - e s 0 0 0 0 0 e 0 0 0 D 8
>= 7 f G SO O E 8 8 8 EO S 9 0 9 8
- O De t >e 5 ,
- 3. >= 3b 8 0 8 9 '*
t kJ B e 9 0 e '
has as S EE 4 4 0 0 0 S 9 9 8 8 8 8 l af g 0 9 9 eE 4 9 4 up 8 8 8 8 4 Nb u O 9 9 4 s ame & 9 9 ' ,
n>n e e
. e. le. e. e. o e o e o e '
O. 9 9 9 8 9 sei em 4 9
+
se 43 O e up B 9 8 9 i D 9 9 9 8 9 l E 9 8 9 9 9
( c*esene 2 s3 t
e SLO 4
- O 8 S
8 9 S S 9
9
' I-DD20 8 8 8 8 e e. 8 4 S S
>= 93 0 .
e 3= 8D>S S S S S * ,
9= 4 9 ).J K B G S S S De 4 n aO O 9 0 0 9 I D SOEO 9 9 0 9 eS S - )
g>e e m. ma e e o E e S ee e -
s g
.J 9 9 9 9 4 5 !
e e t 9 4 e -
I O 8 9 9 D 8 _- I e eE .
E e329 e ee O .#,4; ***
3 s*uo e - ..~ )
z . 2. e. e. e. - e o e o .e S 4. . .. .So S E D 9 9 9 S * . -'*. _ " ;*."= . . ^ -
i 9 9 - 9 3
g g Dea g e B
e3 g --*(-' '"
~*--a=-
- 1ha*
+- e- '
S 0 0 9 8 8 ~
9 9 D e0 e a 8 +
s S S S S -
8 8 0 0 0 5
e e a ee, e .Z' y --
e S e oe eg e
g * * - . . . . ..
g g g 9 9 9 9 0 0 ~
8 9 0 9 9 9 ..
5 S S S S S .G e its O tL S
9 9 S 0 9 8 0 5 82 2 2 . ** 2 2 X
0 D 0 *e me **
e p= ' 0 8 ~ > D= -> > . D= ac. .
- 2. .
3*'
A >= 9 9 8 8 9> hp the -- 86 ... .
4 t 8 0 S &. O InB . . Sul . h3 - - e ---
.J *"r"*iv
.e .A A
-. :. T S
"* :-Ma 9 .D 8 8 D J .A e .a.J e ee ae .J 3 3 3 3 3 9 9 9 9 9 93 e e 8 9 6 8 6e a e , e -
9 S
e 9
8 e
e ee ee- -e e sus 8 me es' me as -y m>
we
. De ms me
. . as ce e 3 8 e3 . .
e D g
G a
S S eg S
g
- *
- w =w.
e wn- =w .. be. .
g 8 0 0 50 8 e SW 89 e . $1 '..,
9E S S e e ,e e 'e a ee 4 Os -
Oe 0 0 8. 9 +-9 9 T'* ' 9 S: "
.L.
6 use* -ve- ' se e~~sur
.8 8. 8 ' . . _ . .
.ee9 ee aS T eas *" as ee -- ee e me -. " * *- _-
- e-.r - .
'~e. _. -- -
~
e 1E S e a 8 e-e--, ee . e - s '.O " ' ' M
- e- -
ot taa e9 e >- . S e eo eo ea I e s-e .'ee
- e. * . .e.-ae,. ..
W
"."...s' e ~
-.dr- AL ..-*-';..
S me;- eo
- .- - - - -- .u w .
. eo e 9 w n -
e
.-':==-- - .- . -.1 (s
0 - - ee e p.- 9 m o.
e ..
.S e 4.a.
E s=m--
Ca. -
--., . ,m2 -
-w.+,..-
G aus 9 e =e em - -
e J
e as e m.:
ee Fe a le o e s.e. - --
-< t."* El . y'
+ ~ -
e, .. O. . . .
.o e. C., e.
o, -
. m-e -<.
e m .:- -e
.m mg- ;
0-7
~,:
- -;.3
1;
=
. .. - n- - w -
. cg ..
s._
.; .g ii
...n=........ -
e . e. e t e e e e.e
~
m,.
,O O . .e . e.
. 9 . -. e . e .. e..~f. . . e=..~e. 7. 0. - e ' e
g* 6 82/06/06 ~
Ct.404 5 - - - - ~ ~ " ~ - ~
rAst 3
~ - --
& ~ 0UTSTAh0!NG~!TEMti REPORT ,4 l HUMBOLDT BAY PGSE 07En OPERATIONS ITEMS .
u -
N R Dl . -
-~
- D'CMtf-O- !?tM.NUM TYFE FOCLOWU#-- FDL10NUP'- STA'fUS" ACTIDN 0 ATE DESC8tPT!VE ,
) ,
BRANCH REPORT NO. TITLE.
t
) ~
=
l i
3:
3
- ..................................................................................................................................... 3 50133 IB=T9 18 IE BULLETIN 0 0 AUDIBILITY PROBO ENCOUNTERED ON -
- tvAe 0F ptStoNNEE Pi Wr w0Yet .
AREAS . 4 l 18 79 33 IE BULLETIN 8 8 POTENTIAL FAILURE OF ENERO ..
" TRANSFORMER . i
!B.79 26' IE BULLETIN 0 0 80RON LOSS FROM SNA CONTROL < -
BE3DE5 ,. >
) -
~ .
IS.79 37 : !E sutLETIN 4 0 LOSS OF NONCLASS.i.E !st PONER -
SVITER BUS DUR!bE DPERATION . t
) "
. w
. IB=80 01 IE BULLETIN 0 0 OPERABILITY OF ADS VALVE ,
= ,
PNEUMAY!C 3UPPEY ,
)
. i 18 80 86 It BULLETIN 8 8 ESF RESET CONTROLS . ole 8 RESPOND w 4
BY JUL 1, 1958 . CPTE FDK INFO - :
)l ONLY u ti
. 18 80 08 IE BULLETIN O O EMAM OF CONTAINMENT LINER -
=
g' , PENETRITION NELDE W NESPONU ,
l ' SY JUL 16, 1980 . 8
. )' i 18 80 11 IE SULLETIN 4 0 MASONRY SLOCM NAL'L8= REPLIES SV - ,;
=
=
~ . e; IB.80 13 IE BULLETIN 0 0 CRACN!NG IN CORE SPRAY $ PARSERS .
) -
8!
. 18 80 18 !E BULLETIN 0 0 DESRADATION OF SMR SCRAN o
- DISCHARG[ VOLUME CAPABILITY
) . s
- 18 80 21 IE BULLETIN 0 0 VALVE YONES SUPPLIED SY MALFON' -
FOUNDRY CO. CRACK FAIEURE . i
) . - '
. 18=81 01 IE BULLETIN 0 0 SURVEILLANCE OF MECHANICAL
=
INUB8ERE~. INSPECT ACCESSABLE .
) ; WITHIN 30 DAYS .
4 3
- )
D' __ ___ __ . _ _ _ _ _ _ _ ._ . . _. . _ . _. .
I e 0 e $e e e ei e to 4 e i
e e e .e a e
' s e e ,e e e e e a :s e e o e e ;e e e e e o eo e e e o ee e i
ens e e a ee e
- i e e e oe e e./D e '
s e a ee a e o e ee 8 l-e e e ea e -
( -l ;
e e
o e e e a e ea ae ee e
e e =* es > as
- o ts me o E
O i= e e
e e ee aa as ww ee p oo > en e
e o e oe e .a no en. =o k m. u o > ts as e e e e eo eu o o e. ow 4 e=
- aE e o
- n. m e e o ee e me >e se 32 =e t.s > as as a.
e e ,e o e a. 2 2 en a se ee en e z oa e.e e as 44 o % as E 2o 3e%e - et e e e e> se
.e ens e
e e
o e eo e e- o.e e e N as e s es as o og ma es e m en a sie t*
e e e oe oe 3 > as N s.e os xt ans l %e ao l
ee e zo e.s- -u ha as le u 2o u we o.a
_e ms e, 8 e ans e>
e e e o ee ee e u z >w ma ce se r.e a er se ou ens.ee.3 >
e .* e e *e e z. = ee a w in, so :: N es e am e 4 D e.- 3 a es se e p. ens e e ae e a=s a ec z an. >= m o a ens es e >g se . as e o* O as I >I as i e e>%
a m. J e e .o e eei 3 ' ..J ** R
'io
.J >
e zk se k es E en es I e me e-eato e e e o ee is e ee2 as so e> e 4x J ens 6.s as pa r .> o_as.> as ha zI ou
- er .e > ->>E ens o t as o % e si en ac as h ==
e u n- e e ee a eo m.
o r e>
D e.
- a. e- ma u le ens >4 za u2 u es. E >
e as o e o e ens ens e p- e= o o > as o pens l
e ens o e eo e z as
- O uz z ins i
ep e e ee e as be z a ha et ans m. e, as es .a ts ** m. p aa e i
e e e eo e er. o 'se .a as en. a wo ma ins H as ins L.s > er as > oe o se a ee et e as w ee t- > .en s a ha ens E ins es as se o hs a u aus ee n zia.:n s ma.
o e a le e an. 4 va a o k ir 2 e na ene 2 's ew .= > si- ee p e e e to e e a w as a e as O se e e o ee a m.e e =s-as ha ens - ee a e o > r4 ans u se 2 m. so 3 6. z ens a e o ee eak at ut E e ' as e- o s N as at 4 ueu ens e=
eo eeI oo 2 3 pt so 3 a ena t .E w > w e se o e. Ma e
e e e e e oe e>o se a, o es se u ans > wz en, at u.e e ms an ee o.e L.J > et eL e ** xas4.aas
> er u. m, oe . mp as at oeens as u es u a e- > E na at m.
e o e e LJ et
- ar as zD ens at m ens m.
e e o eo e o les ma o o= ..a e o ee a se u e n.8 > u ens o 4 s es e- ts as as as. is a m. o > D i .s m o m. se at ma e
e a e eo an ens 2 a.t a .a zoas e z 'en ee o ens e.ens en.s
- s is ans x x ans e as o a. a s se ans o as se as e e o ens as e o e leeoe e r e e e e e je e e e
ans e ha is e e- e e to e a
' ee e e e.st e e eo e e e e ee e se e e e eo e
>z e e e ee e at o eo e o eo e oe ew o e Is e e
- m. e- e> e e 4e e e ans as eu e a je o e e as e e ee a k;et ins ei a e is e e as a. eI e e a e le e se o e
e are z = e We I.e.
ins eD e e z>= . e- e. e ea e eo e o o o o o o e o o o ** ens e as e a
=e a. e> e e leae e i so o e se e e je
- e o e o e
z e e e e
{. . we w e e e to e o me e ea e is e e z ss e eL o e e ea e as a. epze e oe e
> ex e e ee e os > e o e- e e ee e w as e s at e e oe a 3e e Jo e a eo e o e o a. e e ae e
o
} > e an. ens e e o e
. aa e e
at e s
e e l,e s e.
ee o
e e
a 1 o e e o le o e 8 e e e. e e i- o32e e je a e i
it 3 ezue e ee e i 2 .oze . n. . e eo e o
- o o e o e o o o o t
e J am a e ee I esee o ee e 6 e o en e e eo e e an. e e eo e a e e ee e
, e o e ee e i e e e ee e I i e o e ee e I . e e e ae e l e o e ee e i o e o ee e a e e ee e i e o e eo e
- e e o eo e e ha e e oe e x z 2 e n. e o e a ez 2 z 2 2 2 se 2
se 2
me ce se e> e e eo e me me 2.e o me me se M a=
ee e> > e- e- o- > e- > e- > e- '
e > e e s e e o e aw me ena ha ens w ans and as ans
.a ans ha
.a e e o e o e .s a .s .a .,e a .s .s .a a ee ea .s a a .2 s a a a a e e e a a 3 3 3 3 3
- e e e le e e3 3 3 3 3 3 3 em a se e e a e a e e e e
e e
e e
e jee e e e se e as as he as ans a es ans an en.a e a e le a e me ans o* * ** ** se m.e e me me e.se .an.s
. oo I e
e e
o o lee o e e i
eI e e e le e e
> as as as e .
ex e e is e e N.*
W
==
==
o 8es o
ese o - o - e.
an == -
== = -. !
.e 3 e e le e e e e e e e e 4 e ir e e 's e ee e e e
e o
- s. e e e e e e '
o e l
e o ee e e
> > > e-ew > > > > > >
I t
a he s
e ans e
e e
e le eoo ee o e o e e e e e e e
- I e e- le e e a en e e as e i e o.e e
o e e
is e e eea.s me me e s.e ee -
e.e o =+ e4 e.e e se e je e e
(*!
e o e e o e e e o
! e e o je e
.e o e
e ese et e inn e e w e as e e .o e e em "
eu e le e =*
eoe
.o e o eD e e eo
% ea e e oe a we i
- ses e oe ee e o e e a ee e
~ i
- s**-*--~~- >
Ja3as2 asat aaumniasa-zI I : c I ma aaE l e t anat aatraiuaa1 x3 must as4 : sa7 :.:
0 O e e e e e e e e o e e e o e o e o e e e
[5e(+w,IN}
~
r f $4s <a (fdv P[~
~
9p
- p.Metrhew
$} hey N a c/w M en a . Fx+ce
)k Ms d &p g a u xe sv4 /.
fiYb["A %"'~a 4~% 7 __
. :a- f ~4 ~n, em ,. ,
m~ s+ ~~w ,-,.
/% j - l+ E wzd- / % p& cwv,
+ ,
ifd% BiWs &sm-- h D 6 xe aulQfa a 4~ .mssa a h$
. k o ,,; t . 3 7 ' '
? Cons./ af 5/ remucci Ac/ case Sirn? .Sm/~ /sm I?Are<.{f.afe) p :.
\ 1 1 u . a ... > . .= x= x
[ ?
t*AG -
e of che&t{ kort~ nef an/k 9f eCl ' r-- y * ' " =
- 2 %oT M q u.J.cp a .3 [aw w.,ca.u m i q
*P . s ~,J 4 J- 3 C zi
&p. .g % & -ab - P ~ A ~.r.,r/d r
[ ,L_ Bo y* A A-g fu u4.MaA- /M A42e ~4, d.bl*3 , . tic w . g .
~
M l 3R
%ugs 5
) . , _ _ . .. ..
v .. 2-
. . r-r s
hkj G-11
,g Qw A hcc ei-bG'l-1
/fl06hCUiMf/wce4L. f Qset -b ,
O flup - locfR C0 51, g 2, 9 O f! cane //cc MrI/ a.6.l.gg c ! u syy d e d $ ~ ,h:sc a r., ~ ,ty e W Se Y-GCL M S*W tocmst - Sq. U-r J. chtnt u
- m. ,;3,, p s w ka u dl A d e w o L u ,
f&em W, f 4w/auf' c~ ac - w Q
%peopl g n;dt w 14 a" w" -- y Aq . sae seg {%cvu i< 4 -...,1] w Lj
, o4he+ ful;#g s i$
; - as "
e %k Paw + , D
- fqw ov 5ER.'d f & m c.>rww% %' .
D
$L l)ecn Mn nn &.s,~
w *&snr g% - pa /ocmq --> y 6 -any-as Lp eq' q wae/p',u7 m+.1.7.psn~
. 4 M ap Et Eccy, ,eLal epsearc M e ieu 4 t w n ( - , O L
- a. iels.A 1
'n/w s (Mes &n edrtN
] . eaW EtC w2d &
'Ar,, .-it A%.c pw h
- 7 5 /
s1,ze,nAy ., Gefcer o f % Aam
< m I
c L 0, .
,, ,._,_ _ - - . - - . . - - . - ~ - - - - - , , _
w__. . . < _A, 2A-- _....__g....
.. A e. sam % .-me. .d*be . . m. . .
.} g pp 9-ll 84
-( % k gW A's L n , Pn3 e z A L g l
? .. Y C. Lkki ,
C M, iygg Ptn ~i 2R
~
- 9. CMCh Soto> ' .
~r -6.C-COlcja. [k W
0i !&\ 5 on Sen;e e 0,em; cJ n /l) fvAcdm lheet. g & k5-fI b #* y V - 5 S;sco s.3/en ] Ac/2 & C~enf s
- sed Affy
+ A c(di km a I re&;c hans ~ sete a a.2 LV k 5eV W,1 7,e(, h
[M' - Mb1%etb~v c m ,s ,. moyaeaam a
/ _ 4 ____..__.._. _ npsetcus
.Sh49A p%ra,yss
__kra L Mnta wws
)__AA-aap p poms-wa, s a4 ,a
\ whh c s;L 4 , G y u m). u - p % y ,.ae. ,s.
'N Ar $ h Nt;ckr lMk c .
, w(& a4 eaa sw t 6 <A ; Ac/tc doedmxj r-s EIS?%, -aguz
! + pa .- b uA <F _- -
l c% M [qw/& d y.Ah .-':3A
~
2L_'.- -- . ;
n, . . ..- . - -
~
- y ; ,. -
s
- v. -
~
LICENSING EFFORT
. e SER SUPPORTING ":
I
. POSSESSION ONLY LICENSE
, TECHNICAL SPECIFICATION CHANGES i
. DECOMMISSIONING PLAN i SAFSTOR DRAFT DISMANTLEMENT- ;
. QUALITY. ASSURANCE.. PLAN l-
.s ,
1 e ENVIRONMENTAL IMPACT STATEMENT O
~ ~ '
eu O 8
% 6-
,e*a% r -e N M- *Wh.e Oes e h ge _, w.umur + _ g. gg, g .emggtw yet M e aM MM-'** _
f . j I TECHNICAL REVIEW BRANCHES s CHEMICAL ENGINEERING (LEAD) e IETEOROLOGY & EFFLUENT TREATMENT e RADIOLOGICAL ASSESSIENT e OPERATOR LICENSING 4 t e ENVIRONMENTAL & HYDROLOGIC ENGINEERING
~
e 4 k (
.-wwg-e-y,. m ,,e. +.ee .-e-- - - -- - - - .-e- .,r.- .w.m.-=w,.=,,-..,,a- - , eme .g -g.. ,---g4gm e p-3_
.- - c I,
..-1 PLANT STATUS
. :r i e FUEL REMOVED FROM REACTOR - STORED IN SPENT FUEL P0OL .j ,
I e CERTAIN PIPING SECTIONS OR COMPONENTS REH0VED FOR ALARA . )
. e OPEN PIPES SEALED - CONTAf11 NATION CONTROL .
l ! )
- e SOE RADI0 ACTIVE WASTES PROCESSED AND SHIPPED l
e DRAIN AND FLUSH LIQUID WASTES PROCESSED i l e SYSTEMS NOT NEEDED FOR SAFSTOR WILL BE SECURED AND ISOLATEDs , o CONTROL RODS AND CORE INTERNALS LEFT IN PLACE i i l-
- i.
e REACTOR VESSEL VACUUED AND HEAD INSTALLED f
OPERATIONAL SYSTEMS NEEDED DURING SAFSTOR . f l t e SUPPORT STORAGE OF SPENT FUEL
. i.
e IMINTAIN ENVIRONMENTAL CONDITIONS FOR PERSONNEL PROTECTION ; l . , i - ! e PROVIDE REMOTE MONITORING AND ALARHS . 4 l / l
~
): e COLLECT AND PROCESS LIQUID AND' SOLID RADI0 ACTIVE WASTE t 1 ( FIRE PROTECTION ~ !.- 1 l 4 f i L. . .
i OCCUPATIONAL DOSE i l SAFSTOR (30 YEAR) DELAYED DECON ?, ;- l PERSON-REM . MAINTENANCE 21 7 35.5 PERSON-REM
!i'
! WASTE MANAGEMENT - 36. ..
o ! i, MONITORING SURVEILLANCE _8 . l h~1 TOTA'b
'. h.
l. t GENERAL PUBLIC DOSE j. , SAFSTOR DELAYED DECON 10-3 PERSON-REM 0.7 PERSON-REM E i i l i
^ -
?
RADI0IS0 TOPE INVENTORY' l' i
.' t- [i i' .
ll CURIES 'l c< e SPENT FUEL ASSEMBLIES 1,200,000 l; i:
^
.. e ACTIVATION PRODUCTS 12,000 NUCLEAR STEAM SUPPLY SYSTEM 32 . . TURBINE PLANT SYST M . 33 . l! i' SERVICE SYSTEM 32 . WASTE DISPOSAL SYSTEMS lli ' l . l. [
. r i
I
. CONTAMINATION AND RADIATION LEVELS : i V , .
[ s REMOVABLE CONTAMINATION: 10 10-5 CI/100 cM 2 A/ - t 10 10-7 x Cr/100 cM2 y i:' [ 4 1 i [ AREA RADIATION LEVELS : 1 - 110 MR/HR 47 . i t
- 3. .
j ii
~
. t i
I I l ! j ,
- p. ,
.- /- . .
. EXPERIENCE NOTHBALLING/SAFSTOR OPTION -
WITH POSSESSION ONLY STATUS OR APPLICATION POWER AND NUCLEAR SHIP REACTORS POWER POSSESSION - i i LEVEL DATE ONLY LICENSE FACILITY MW THERMAL SHUTDOWN ISSUED LOCATION - ji
~ '
VBWR ,' 50 MW 12/09/63 09/09/65 ., ALAMEDA CO., - CALIFORNIA i FERMI 1 200 MW 12/01/71 09/05/73 MONR0E CO.,
, MICHIGAN i-INDIAN POINT 615 MW 10/30/74 APPLICATION' - WESTCHESTER CO,, .
UNIT 1 . SUBMITTED NEW YORK , PEACH - YORK CO., BOTTOM 1 115 MW 10/31/74 07/1'(/75 ' PENNSYLVANIA HUMBOLDT BAY APPLICATION HUMBOLDT CO., UNIT 3 220 MW 07/02/76 SUBMITTED' CALIFORNIA . l N. S. CHARLESTON, , SAVANNAH 80 MW 11/70 08/14/81 SOUTH CAROLINA \ I l l
n p. . n .s a . s. j . .. n
!' i .' y -E 7 Af
~-
s, .x -
- l. >
3 .
- a -s % ,
e - ' a b v I 1 i
.I
.NRC STAFF REVIEW PROCESS .
.a I FOR HUMBOLDT BAY UNIT 3 i
1 DECOMMISSION PLAN - e j . . 1 , i l t-i e
u,'- j -i i :
. l h
.- TOPICS TO BE DISCUSSED
)
O CURRENT REGULATIONS AND GUIDES i 0 REQUIREMENTS FOR. POSSESSION - ONLY LICENSE
. 1 e
j 0 EXPERIENCE IN MOTHBALLING/SAFSTOR OPTION
~
~
.i t
t 0 I I l i
- , . . . -w
i- '
' 1:
i j i . CURRENT REGULATIONS AND GUIDES FOR DECOMMISSIONING - .l .
.i p i
i 10 CFR PART 50 - LICENSING 0F PRODUCTION AND UTILIZATION FACILITIES - i 4' S 50,59 - CHANGES, TESTS, AND EXPERIMENTS i S 50.90 - APPLICATION FOR AMENDMENT OF LICENSE OR CONSTRUCTION PERMIT - S 50,82 - APPLICATIONS FOR TERMINATION OF LICENSES 1 - 10 CFR PART 20 - STANDARDS FOR PROTECTION AGAINST RADIATION - !I i*
- 10 CFR PART 51 - LICENSING AND REGULATORY POLICY AND PROCEDURES FOR j .
ENVIRONMENTAL PROTECTION lj j' REGULATORY GUIDE 1,86 - TERMINATION OF OPERATING LICENSES FOR NUCLEAR j; NUCLEAR REACTORS J . ? . l, [
n? 1
~
. REQUIREMENTS FOR ISSUANCE OF POSSESSION - ONLY LICENSE -
MOTHBALLING/SAFSTOR WITH DELAYED DISMANTLING i i
~
i l REMOVE FUEL FROM REACTOR VESSEL i REMdVEFLUIDSFROMSYSTEMSNOTINUSE TECHNICAL SPECIFICATIONS ESTABLISHED 0 FUEL STORAGE 0 , SURVEILLANCE AND MAINTENANCE O FACILITY RADIATION MONITORING ,j 0 REPORTING TO NRC , 0- HANDLING AND REMOVAL OF RADI0 ACTIVE WASTES 0 ADMINISTRATIVE CONTROLS ' l' L f l i
t L
.t.., . . , ,. . , . .
J I I ' , '
' .' l- '.
f1I{I
- i ' i ,
I " di .e,
- , i ,
).
. ![l l I '
i 5
.'.i!d.:.I
/
.i
=
,e
..u
.l1l[ v i
.;i ,,
n'i
.i A d'el';l ' ~
i 9,~ ,yl ;i i '. #c'j/ r 1.. ig. H fatI%' % e i ,'
'{gXM i' i
* ' j ' '. -
!( f'!:
i
*h N t '.
; . i./f lii;L ' , ,1
,- 1' - g, ; !
.j.j*L
'.,= - u
\ 1.3 B ._;*,, !m ,
t- 5= 5' I ' - r .a - ; lL J , i,r:.~rRFF,li]Dj;g,1!,i'.'
.t c :.,j i.
g r ;
'i,ODMXili1ml
. ~
ei
- i ..
[.. . L'!Fh %44 i. ll i li i fR - t jiIIL10 :0 Mil ; ,1f 4 ' 2 - I h I. I! 7:
- I l9 H l ! $ FG i-[ 11 Il 4 -k d4 Aboumi -ljl
=
loj.J.J . y WM N ; - 1 i 'I -
/' 'I}ll
,Q!lIl 7 4$40$$[ '
o
' i ,. o
- r n u1e r- JL _.UL U,,NN:
i 11
? ! 3 s hl
- it r r E m iij 1
3 is . l' " T I'D i, ( l' S
' 3$ g I _f 1 3
_l i l' .' .
--! i___ i i
"$ l, s
,!'/
.. k I' .
j M i p-5 l i
..b
.g f .. l l 1
.[ . 12 lli 4- .I ,
n
; , I a .
i;g . . ik l' l.:,
~
. Ij i l '[ .
il l
!! J i
Il = , / -
- c. ' , '
J,)
, g '
d Sj; .;.
- 1. ,.
f r. [/.,#j ['h k h , u.E.*
i
- G
;9 ' ~
l t,jj , p ' t' ,, .w m , a 5 Ti.'ln a , FUEL ASSENDLY 4ppsovEo NE'Me -[ - A-2-7' TE FIGURE PEV G/G9 y 4- 2d- 71' SHEET 207 2 SEviEwCD et CN-SITE REV:ElvCCuurTEE 5 f-g ' 0E__ w 1
~
j~ ^ j
=_ .. - _-
3.; ' s S , N $ 5 ga~ l llI[! g
=. %, G L r
l' uZ i lEG y\
,B 7 I ) , ,
p il i si 9 l 5fi sll
=
2.s
~
j;ll.n,:.,,i i f '/P ' J E
;,r , . .f, fi. . . ,
'( '
j / f jg I~ - 1 I if L f ji, ] n
- b. ,
I l 1 : I! I ii ;! ! lf .oi ,, ij! jil ! !! Ii n!! r lil!. j IIi ' i; fj
,i, inislti 1lt! jI r fl!!' l<!,j!,
1!;ff -
,!l!ii -
j f, i
! l!ILI l ! fiji !! -gg-li i bill fmiin !, i!Iituna !jJIljf !;l[lIfll,k ij j f!,lll;a!,!!! !!
lu!' na,,ilh i, p i ll Ib - - - I si I
,i
, v I fy fIl l i '
fly]I f f['I li f i-I, f l 1 <.l , lifgg,i-s ipll31,
!_lLlihlp$,L1j f,i a 11 l
i il"y _<,t ri.i Jh 2 3 ip,!p.jo,![ 3- I'
- ar !j llof Ir p[ [ ..
I
- ~ ~ - - . . . .
9 ~-
' ~
- q
- : S** *se ev . . . . - .,
y-_- ___ ___
.g i, 4 $
k$ 1
- b
. . t .
e ;r
.s
.e e.r I s .
EN
!'.sr3 # g l 43 c ;
Il~ ' t a
!g~g5i s.
d E i p- . 6 ;' ha! bgs1[E!!.ili!!n!.!ii ! ! s.E!m h. !!ys@l! .} - !_! d ,~
\
$..!f j!!!!Etjf-. i,. W E 5
' i! .
41 ' . I[ J'..n e . ::::: nin::c::ntat.ye p' y- n
.c
\
l r% -1 *[ m 1
-- 1
.e .
i ik;i s c . ,i
- +- _ y! 5 1
'.l 1 1. A] x ..
m.4w [l 0
5.. 3 :.g _ ag 00 gE 'O 2 e_4, c .
.z &O j e V. C & . n .J ._ _D_. Ts t 1 0 Q - .* Cj i 1 _8 8 l, i Itt_ [ l f l ji - - I ~! E I~ r r- -- -- - -- - - ,-- E ,-e m p - i b !.c f ~,-g7 r1 ei , p 3 g;5,, a - - - ! 3 a, i = e i, w&a J h m!' h ! l! Ih"'b E { $h h* ~l_ W M I I L_. v- -y ! g --!l ] ,, _ cr l il l Fr + e a 41 9i i i 'n
- i. lie r- i;s g l ,
l 4)O I jI "s'I -;:
- l. b,M_
.i . : : . , , i 8 < ui !! [ It iM: V ! ? ;i v4 l ' C r i E l' f *- l d;& !$!e&TF [ -u N u l ,. t 8! / _t . ? 0~l t !.W e --*~m...--- . . , , , _ , F '- ' s ....,f _ , ,. ~ ~ - ... a.- -- -u = - - - - - .m..- ~ ~ ' ' ' ~ . - . ____.m. ,, _ ,. _ ^--17 ---7 , Y. y *i s, .h .C. A ] l' E f <:2 g < s Il II *} } } M .l: . &a$ ' * %J !! 5 W J ;!.. g.. 4 r-1 ea cr 6 ,' ~ i, "gi 5m 3 o 1 Hgt; II EE I!l:gl, l 2 3 e. i i, i { =b I s . E" 2 5.g 5 sig s' >- 3; [- = ! Ejf!G '!I [' E ' ! :r 2 "cl! $l3! u922 II.!.!.!.!.3 )!!.u..r s.t gve. t s - a Pp l! 'o * .I E . 1, .. . c. - a g . o iiiiiiiiiiinitia6 ~ ' , %; 'r .. E0 ; jal 38 ~ i I I :3 - i .=r na ,, g- ..__.._, - g ,,- , [J .. - g. !23 ~ a-3 ~- ^ ! E D. .F [s ;d '{_ $j, QL,,J D1D .'{jL ' a
- L .- gm I % v
.. s_, =o ; i t: ,s. .-l , i r CL. -s s , (Lv-- o e, +! i ic ll . IO* , e $$@j,._. @iil n=1 --- l.l l, r p ( vp i , i O M IDM., . :.. !!k- hl L. - i; ! ; !!! pe---- 6.lo*r!! --~r t.* i , g :sig-r, ' UKWFMM: 1- g u - 't ! ! d)@)! :L=.:ii 3 'D'li , i F P :-- , Y' 3' i
- a3 w .. i ,. , i s ,
re h' hf ~& , ^ ' =$ l l 0, . Ih'S t Hi a g - ut si- c , !i"i , 3 -l = -f g l T gi . 1 " -es--a l l i s -, g I i is . i. E s 41 gli~ I o 44 " L o ; p~ ..,-* -3 a l b. at . t. gg l . , i, i ., o . .. a . . s ; l :i --eg i g . 5 :, I : < .. . 4 1- Om g ~ 3 li 1' ;. Y- B . ! 9..i 1 ' A N u s;bM78' l "t y _L o I4-': , . , . , - - - - -'%w w .. .ma - e gu... ,y
- I
. . r "' L ~' ~ T :.~ 'C'.- . T.. . .. C- --. ?~ . ~ ~ ~ ~ ^ ~ ~ ~ ~ ~ ~ ~ ~ ~ 4 0 , O O , W , a e S M , M a m s,tt h{p H, Ell l = ;e .x = 4.I. i 1 s s !. s , 8 i ,g t ) hks:: : : " n a "E 7.s r E g y, ga ,p4 r. . , n gE!g' ' 5g 2 -. -il.i a 5; I.5 2i. S 2 4 t--i e5og o m eu e$ -4 3 i s .!a {
- I I
- g *@-)g s < b ..g : .,!
I J @gP $.. gI ' j !!! *@ . o, a I %s si. - l 5 , j %. $' h %NA*5.9{.n 9 : }y 3: g 3 }.;.M, sti' e +y g ., ; ,. ss W r , s i f' n' ." $ "h 9 ,, k-CER: . , g; ,,I I --f!LO = ,, 4 W Yag (_ 5 4 ) c . _g..g i a% r- . - - E i S = e= u I,,,,, E.: s 45Q ' - i. j Ij?it- [ &# ,1 f I a g u ,. a 2 il tic-i j D' s 't 5 !$ R$ > . , i .. o f. < : __i a Eh E d = =
- ., gik 1 m, [,[ h .E taf~ I ~'
b 5 [ y * = ...,. e a jl [h ., s :. * ~ yfw %2&e.lxN [8-- - .
- s. m.___
~l,@ , *;* _ _ _ . , ~ - ll:T,a* s--*'% - - - -d , Ah - *! J . ~ ! @,:: : [ '-
- I!l;7'D- l_M@N 5::
R p k..j" ! 5f,i#@$5h"h _I -hj ~ i :rm d ,g , , m. . x . t:' F-
- g% @.4 @ e 1i b W= i
= in-4 -r rPT. + 'em e rr- r? aarbers 7ve>8tts 6 r4] M , W f"IFW7 e ** Es QQ TJeuvMJ CIIsj afe **** l ~ . . . ..- .. , /. . . . . . . _ .. t I < . . o o. o .z .s . , e A C b ' 1r S k ,' ir o [U I=f t
- m. , ; - . .=, :f S4I,h <:, .WL , > g g .
;. : ;E l g }}y ., ; j e 5 , e. g g s. a - A , :- 3 ni x 5 1 r , 3 g e i," : s q a. i s i: " 4 ~ ~ I 5 < ! I i I ! I z. 5[!g -! !g
- l l g a; g.
3 1p. ,- g e! - ;..,.. *[j pQ l s l8 ,,- a g . u e , - , ., d 5 1 us - m e-
- il " E '1 E IIa s .l.,. .g co a' f ,v,<a V- .r a !" $r F r{ eu I5
.n s? al.v r 1 -* a M a . s ; 6 - 5, s i. ., . a a n I
- l. . l 5 8! : '
!, !, i *: 8 9 ? p v l ,, , i v' a @ x = y:= '.? = x 8n "- -b : g .v i 8 V1' ga a {.! E 8 3 = 3 . g 5, i i,
- s. *< >-
!.d) c-w"I - p" of3 ,u x = .55 gi-i l .4 . 5. o u - Igg..4g: p L ',n_ '$h) E-M @ i l i"j @--4l tn:: !li '~- . - I . = e ' 1
- S> r_ _. m m '
,n _, ; 5 . 8 *=! l. e # s - 14i4~( +-~ c= o1;, - * ..I . - g A } - ,.L . E _ . _ I <+HH i= il*C.g. igg n !, . -g g i 5 l J.. l l18j BT.Grs;-(E5 ti - - - - - - . - ,. { ! !ill g 3 9 . j e j ghgggi * ~ { M- - _ - - - _ - - - 2, l{. k .w. -
- d. .h .
. d 3, d o S q*} g ..=. . . f ------- ?? , g g g...............-...g
- mn:$, N d '
v 1 a j'f % S . ,.. dr . "4 m
- y :. q... q) %
), I a ; 3 sn - 5 's a
- v*
~. e a !i' 4, T@4 , i. 1.+- p" - .q..af LL ig / t i o . i gS 6 d ,l sy<. . m i 5 m e, "" __. e'--9@. i e 4 . =
- s. i.
, i. . . e g fO 2 ** il 4$ J Ij : g l . - 4 2.- @44 ll ; ~}g N - ! .. 2- =.=> . , 1 1 i i U . . - : : se i , g,.! . i .'di rp 5 g 1.E 99 I "8 su! I l" i !e2 .ds .!q1l r,1 v mg ! P. g i1 s . l,s[ fu 8 fl=a ? g;i "e !I ~ I ' gg)f !..iEf l" I -
- Ig .= i,j e"
9 ! %#4.Q js,l i.a m l 'iji, ii!},ilmi}I '11 s I1 rh . ~_ ngygg .AAI ,a g -- .3lg O FFheyas dessetW.gemme Augu . _ _ ,;7 asswr: // 88 **
- L Nigp N ' e VP w 3 Ge s
No4FA ! Jlemer AM J 7//PW 67 I W dk . - - - - - - - - - -. - - - - -- d 4, . . ..__ .-m,m _, . . . - - . _ - - . . ll il . _ . _ _ . :1 'l e o o . ,u e z - , ) th W I SI_YI,i!l V 51-TC)-5!!i e- 8 i ! ! 5, , a H #k 1 1 '- x E ar [a: s r b '- , * ,,!=! , E ~ l !g j N !.E $,2 e.s sw kt:m. a o= e + q_I; g o t, ' g g sr. e4 y S E e *4 a. -. a 8 jg; = o j, -g .c , ,.E gj O !s vet S = '!a t : 2 i El gr g gg 3p !r ;j }, "!oc' ;g s g 35 :- gi 2P gy1 r , ! \ At 'h ::1, s n: Io ,,, - ~.. s ..g I 0 !!* u 15 g :E a. !' @ df.* s ! . 2 7 f i tj j h- $ EIN .',! ,! - [ @f c , a igd "~ _zgo i PP . 4-fB ! I I - i, 1 8 . li w j ji, i i. %g al,i , =%_ im:t- fi!; a A t., %j, 4 it w em " ~ ,_ 8I E g i 'i j 1',lt-a,_ lid _"J p-,y0_ y@. s-cs+ Fl. s!! y i,I ,;ex .i _ W s,. 3 ")n, . l-e l B a$ ~ 4 r 1:2 -- -l F G /-. == 1 4 v,1 i, I *"*a 'E, f m f . ,Gh t il h. is,-g a @- 2ll-pt__r , 31+ l g. ij.um een me.,l ! r. . . 2 ; ~ a r fg m k, d g *[l lf ;2 _@.y)/-, ;I !@iT " is h, @a is C5?j-as h%:r',s 4 ~[I .= - h e. lI e-*I i gs g ', i '
- t- "i @,
[ r-.------_--l ,y kump' g_ p-k llS =bl s ~ ew -=., =_. .. l ~@ = y o.ggE"~ A- (@p .., Ol . 4 E. 8 - . . : <!! !! . .i u ..=_~e"_ __./ , .l 4 , ,. .Gud 0 e~-2Mg..s ; e-g g go -mm ; - ' -M y- - j .! ; l .t t g!"pM; .
- t,aW L
_g. g_;i n_8 ' i g e us ,,, [{. s _ . ._ m i ' i , . -@E@. . .@. .. i ~ e d! _c : ,e ,l ..i.? pri6 p.L w %.____4, s s .s . 11 .._ i (h - I Ik I! 8 1 .@y' g ;.! g! r , ,- _ g-4 pq, , gg e9 9 , ,. , - a, .. . ,- . ,w w a-- 1 ~~ . l =. - = - * - == ,I < esf.esie answ. esm 7' # ' * ~ ' PGwE P ~ 3 magna-comem u.a. - N*' NUCLEAR FIAN! 0FI:ATIONS - Humboldt Ms No. 428.9 e . Rs LsTTsm or cuesscr EPFP Unit No. 3 SAFSTOR Deconsiissioning - , 7 , m ,, Sta:us Report No. 2 , osseriment NUCLEAR POWER GENERATION I October 23, 1984 MR. JAMES D. SHIFFG: Attached is Os.stus Report No. 2 for the Humbolic Bay Power Plant Unit No. 3 SAFSTOR Decouaissioning Project. This status report is for the period ending October 19, 1984. Cost and manpower information are for the period ending September 30, 1984. PROJECT STATUS i Preparations for Decommissionina - Layup of systems not required for current plant conditions is continuing. Layup of the Shutdown System, Low Pressure Core Flooding System, Poison System, Closed Cooling Water System, Eastgency Condenser, Reactor Vent Valves, and che Turbine Bypass Valves have been completed. Work is underway on layup of the Cleanup System and Control Rod Drive System. A meeting was held at HBPP with representatives of the Engineering Department to discuss requirements for the Spent Fuel Pool Cover I and the building to enclose the Radweste Treatment Facility. The ( Engineering Department is working on designs for these modifications. l l Licensina Activities - The NRC has determined that an Environmental
- Impact Statement (EIS) will be required for- the SAFSTOR Decommissioning i
of Unit 3. A federal register notice announcing this determination will be published shortly. It is expected that the notice will also announce a " scoping meeting" to be held in Eureka for the purpose of obtaining public input on issues to be included in the EIS. The date of the meeting will be published in the Eureka newspaper. Return of New Fuel To Ezzon - A contract has been signed with Exxon for a two phase program for return of unirradiated fuel to Exxon. ~ Phase I involves sempling of one fuel rod to determine any accumulation of fission products in the fuel as a result of it being in the reactor core from 1977 to 1984. If, during Phase I, it is determined that the fuel is acceptable to Exxon, then Phase II, involving the
- actual return of the fuel contained in the 44 unused fuel assemblies
, will be performed. Procedures are being supplied by Exxon for Phase I of the project. The procedures will be reviewed by the plant staff and authorisation obtained from the NRC prior to proceeding under our existing license. Work on Phase I is planned for December 1984. D D i . Peg 2 2 4 Disposal of Radioactive Wastes - Shipments of radioactive wastes were made to Hanford, Washington on September 6 and October 9. Both shipasats were miscellaneous plant solid wastes. Specifications were issued during the week of October 15 for bid ; 'for radioactive weste solidification and disposal services. A project to sample the drums in the high level storage vaults is l underway. Results of these samples are necessary to plan disposal i of these wastes once a contractor is obtained. i CPUC Rate Case - Hearings on the Heiboldt Bay Unit 3 rate case are scheduled to resume during the week of October 22 and to last approximately two weeks. Additional testimony by Mr.J.O.Schuyler is scheduled for mid-November. - ADVERSE VARIANCES The deterni,. tion by the NRC that an EIS will be required will delay granting of the possession-only license amendment and any delay the overall completion of the project. If hearings on either the EIS or the license amendment are requested and granted, the project any extend into 1986. As indicated in the last status report, delays in obtained a contract 1 for radweste solidification and disposal have prevented much of the radweste disposal work planned for this year. j . CAUSES The requirement for an EIS is a result of a revision to 10CFR51 effective in July 1984. The NRC plans to remove this requirement in future rulemaking but not in time to affect this project. Delays in issuing the radioactive waste specification for bid have
- resulted from extensive reviews, comments, and revisions of the draft specification.
IMPACT The impact of the EIS is discussed above. Since most of the work associated with this project can be completed under the existing license, cost impact will be reduced. The major portion of the costs associated with this project are for radioactive waste disposal which is still scheduled to be completed by the end of 1985. Failure to obtain a radioactive vaste solidification contract has - resulted in deferral of the processing into 1985. This has resulted in - the project being approximately $2.4 million under budget for 1984. [
- r m.n--n_,_,.-,-. . , ,,.-,,-----,,-----n p-y-,--
PcSe 3 l l .4 - l CORRECTIVE ACTION Due to delay our the radioactive waste processing for 1984, funds budgeted - for this purpose have been carried over to 1985 and have been included ~ in the 1985 proposed budget. In order to prevent future contracts .w from being delayed, fira deadlines will be established for reviews and l followups conducted to ensure they remain on schedule. - I :g y PROJECT
SUMMARY
I An updated Project Schedule Plan / Status Report and Cost Status and Manpower Status Reports are attached. Due to schedule changes and revisions in wnrk scope as system layups are conducted, the most meaningful information is the overall total. For this reason graphs showing cumulative cost and manpower are also attached. Cost and manpower plans are being maintained primarily for recordkeeping purposes. l eQ
/ R. T. NELSON
' I RTN:ks i cc: PSDerks JCCarroll .
SGebeyehou JFGerace BCGetty RWLorenz RMLund TVMolloy RCParker DAPeterson i JHRaggio DDRichardson EDWeeks GCWu NLZiomek Attachments 1 e e t a
- . , . - - - - . - , - - - , , . - . . , - - . v.-. -.
l ' HBPP UNIT 3 SAFSTOR PROJECT
~
CUMULATM COSTS ! :4 12 . 11 - ' 10 - t , 9- , 6-
- i I.7 4-3-
1 2-I" O' ;", , , , , , , , , , , , , , , , , , , , , ! J FM A M J J A SON D J FM A,M J J A SON O 1984 1986 O PLAN + ACTUAL i I 18 CUMULATIVE MANOAYS i 15 - j 14 - 1 13 - 12 - l 11 - to - 9-I8- 7 8-5- 4 3-2-
~ ,
O // ,,,,,,,,,,,,,,,,,,,,,
~
e J FMA M J J A SON O J FM A MJ J A S ON O a 1984 1985
- O PLAN + ACTUAL
_ . _ . .,,.--g.
..........= m .,... m m , m .. m =. .......,
c j i. . gg . ; , I 4 .
. 5 a ,Id 4 .,
* - ,, 4 d F
- N l, l O N ; o ,o l
g
- t , m - - > - e va w 19 mm ,,m i i ii!!!i I M II l illl!,!!'
l I 3 i h i, . js! f -
!b @U l1Mi l s~ h rU .
I: ii il M j9 ll!!i; l I
,I i
.l
- ' .i i j. .
Ili e l*k
=
I
't q i r i 1 -
th! b ;.:h:i !'!.*! l Il',"liisi i ' int i l J lll i A hi rip.%p1.: r 81rlLlilWh
!n!*i nun is ag g u T le m e 541,111111.p]!!vs
!i,e j pil .
t!f-u
. I si .
l l a I lI 3 i a
. .. ash a i si'da ddie's.ssa.$ai-=ssoass a nei amaaAAiulianajm_uireeagav l
,, g ',i :.
1 i ' s lI l,1.!g n,L))'!. !1,p.iill.g.lllggah.n..,.!m. r l i
. , 3. . i. . .s.s s i l l' i dis ii disiuvieniniiniin u ni........................................... j
.................. ... ;...n...m......... ,
l - j, - I . i i i, , a 3
. 5 a s.
e i 1.s< 3 : m:: a- 5 ' 1 t e t. :. a a l ll .}: e{.d
.o fi l .l ig nd t '
t i M$d fsM4152 MildQ i- n, - - - , nu : I Ia b
- : . - ,, .; , ~ , +,c,,,
! lI!!!illll
!2 ! !! ! -
!I il l l l$ Il h !,
lll !!'!! h ! l l lljll:!'i'
- h lil; jj j !! ; l l
l d: , i
',- i titut i U! gi i ! deH 1: . ,
air lil..ti-l,- 1 ! 5 :. i, i ii- . re !gi
.l ;i
=1 u
a
; .i.
i s "-e "
. i i i . n, , ! i .
'i.I :i.. r e t., -
I 5 p- - *- i!!'M ::1, l
" ~ i. ti ! . .
,,,'! 5 .
I3 j Ii:- ! , i . _ . . t:' '; t j : O i a !: ! ! F Lu
~~
t L. ' - . Z WC4 l[ld n : e, J :R i, A_m n i .,il::',. ; + -
-e= ==. .! I-I i
a _ _s,i L.
~
a, : . jc,.t :a. 111 I l ii . t ll l d aL= !!! u ; jI; . !H . . dll:llli d h l 6i_ ig "3 E h :l.!!::i;ii i IP N u ii.i;'ii!! ' 3 3 I il
;g!
- j. 1'1 l [ hlj.l i ii:
=
!' '3
!i") N
~
I i 5 I IU8E s i 24 3 4 3 d's i d i i diJ aa5=55555=555555f adadadad!!d N2)IlC I:) 2222&S232222222221222222221 I il l i' 'it,i .. l j. 'ii , E l 'I ' ' I I f j i.Iii i e ,. o, ile i
- la"i i!ali !simjjiiia'iiili$$$1'a'i!m$ili
.. m mm2 2
!d I I III o i uo -
l l
~
IIIIIEEEElilllEEIIIIIllillillllllillll ...................... l
***e e .A e e 4 e o e p l
b g
~ a 3 ' , g .
g lj - l 4 { g . .
& 4 % k 5 $ , ..
l4i e! + m a o n b i4 4 W id , 3
%.ci : .
u a u w n ,a m m m ii.,,,, I i . I, la lll !ll!'il!';il'
!i 1 13 !!;l ! . !Ij h ,;i . i! > .
Iq is i ! '!:ll i li !' i
!i Ib l la --y - - - -
i
>l'!'.'!
i
,lllii; l
. g i 1 - i1 >,
1 l .' !! li ; l3 i i i
, j s t al :.
- l. c ,. .
w i ic[ _ ui.
- @Iiil.i:
ii 2 ii l
) 3
, , . .w . ; , . ia 1 5 i i) .'l' i .! l l ! ,I l .i J ': - ' ' '
5 2 ^= ,9 a I,...;;!I;'!, ; '.. - iif ;l i '_ [i . [ Ti uy-%_ l i j3 i .;.,. ; ;p .i :
] .' .
l {Jli
- se -
}J&
a:< l ir
- .1 , .
j
- !il 111 j) !!!
~
ll! , f c h$ - - y y .>- 3d ' i,4 I] . Wl((I u _ ._
,! i. p l i, ! I In I '
I i/l ii ! .. i
'i i
j! u:.'!
- j!
4 I g l 3 i!!I!j!i! j' b Ii! : i 11 - i . li if i lij l 'l 5h ! i III i 1 _I iksf 155 @fiikiM !$i!!iDillilli!!ili> III n ,hihL.. ,! L u l li in n nanssaannuanentumeumma
, ,iiiitti, u u . u , u u . u . u l i
,ij!' '
fil l -liu - ! - s = .n=tsmgna
- n. ! ',s 1 . .1 g I "g 1 es esss=1 1
gnsss=gsst 1 1 1 3 3'3A44 $ 0 l
- t.:12m.3.3.L$e$.$.3.344j.333333.33.33333.3333 :as. e .:
g ,l ll"
! j i ii. .i i,
- l4 i .;..
3 l 54,555Ed555555555555558556585856188888. ........ ........ l
.............,........m...m.m......m.,
l . I
;. i . ,
EI (- c a a ,.
- h t g j jj $,7
- j. ........ =
ll j 1 A h h i(c thi 44 U #i ? 1 %$ % e- - . - y m I I I u i: .v., ,, ,,, ,,,, , , l le id i h . ly J 33 IE !l jjli i l}h 4 L ,7 , , L L" j j l j;i, h i ! c , , ., U ll l(. r i l ,, il . i I l'- 3 - 5 i a
$ E IA 1
a 33 L
.t l
l l l U,.!,i' I ! !! ! ;!.'. i-lll lli Ij m'.i t I s :. '. ! ;.,i'i'- ' h I t ! l
- I I
l jj i illl' ijlI l
! ! .l ;I . ' ! P' !; lt!l;?
IE is '
- : i .,._ .. . .: ! ,:. .
! $1 l>
ll I i
'l h
. '.l
~
~
I i3 l!I i
; .l ll>
a .,'; i jv i s h ;. , ,. l i ; i'i - G7i
/A ,
, ., g_c I l
}; l..i .i . ..
ii il l 1I Mi n i i 'i ' I,ij i 3 i!' .
;g!
l 8
,),, 'i. l :- la I i -
i , 3 I p.g f J'
! s; - II
;s A i jil =1 tip=ix I i
- =g:y.-r., ;.
phTa **jie, - 3 f=~ I gI d y
- g 3; 1
a 3:O' g.se s.J,z R g.R , l 3 g ,g i j j' EY.. *- I ?1 a as , ["11i *.8 iE[!*.**f s 11l33 . .l i *
,, .uQ ii !
i i i o _i:ze i , I I II t
. m s e n.. .I. .as sa _mssgum !i.
f,. g s IhM N NN' NDN_. AN@JI.AN N l a i
!I ,
;i y g lW 3 rashismerms! sed sissa 1
o l,i l 1l l'l l' .I.l.! ' .!..L.~. ! * ! s, !!..s.. s s s. !. .! s. .!. .c. 2 .!. !. L' ! !. !. i l, l .i i i. in n,imm' sisissisimnisonm -
r - - m _ O 01/31/85 766 DATA FOR LLVIATION-SEVERITY LEVELS PAGE 1 e HUFFOLDT F4AY-05C00133 JAN 1, 1972 TC DEC 3ie 1978 REFORT Fh0F TC DL%IATION/ Nur?ts DA'E DATE SEVE*ITY TEXT . 75CS 001"75 C62575 3 CONTRARY TO THE REGUIREFENTS OF TECHNICAL SPECIFIC
- ATICNS IX.I.1.D, " RECORDS OF FERICDIC CHECMS...PER e FORbEC TO VERIFY THAT SURVEILLANCE FEQUITEMENT ARE bEING MET" hfRE NOT MAINTAINED 0F PORTAPLE "ONITO a SURVEYS CF THE LIQUID WASTE SYSTEM VENT RE3UI'ED DURING THE TIPE THAT THE VENT MONITOR WAS OUT OF SLRVICE ON APRIL 13 14, 1975.
7506 C7C275 020175 2 SECTION V, PAGE V.2, PEGUIRES E ACH APPLICANT FOR T HL SECUFITY E0PCE, AFTER BEING INTERVIEWEC AND PRI OR TO F"DLOYFENT OR ASSIGNMENT TO THE FCRCE, TO RE CEIVE A PHYSICAL ENAFINATION. CONTRARY TO THIS RE G U I F E ME f.T " EMBERS OF THE SECURITY FCRCE HAD NOT PC CEIVED THE REQUIREC PHYSICAL EXAMINATION. SECTION II, PAGE II-1, STATES THAT THE PFOTECTED A REA PREDIPETER IS F E r:CED AS SHOWN IN FIGURE 1. FI GURE I CF YOUR SECURITY PLAN SHOWS A FENEC AFD GAT E CONNECTING THE Ibl&KE STRUCTURE TO THE SWITCHYAR C FENCE. CONTRARY TO THIS REQUIREMENT, THE FENCE AND GATF, ON THE SOUTHSIDE OF THE INTAKE STRUCTURE SFCbN UN FIGURE 1 0F VCUR SECURITY PLAN, HAD NOT MEEN INSTALLED. SECTION V, PAGE V-3, RECUIRES EACH MEMBER OF THF C ONT>ACT SECURITY FORCE TO PE GIVEN A PERFORPANCE R EVIEW AT THE END OF EACH MONTH VHILE IN A PROPATIO NARY TTATUS. THE PROBATION PERIOD IS SI) MONTHE, AFTER 6HICH A PERFORPANCE RATING SHALL BE GIVEN EA CH 1HREE MONTHS. CONTRARY TO THESE REQUIREMENTS P FRFCRPANCE FEVIEWS HAVE NOT BEEN CONDUCTE D FOR THE MEPdLR$ OF THE SECURITY FORCE. - 7506 07??75 080175 3 SECTION V. FAGES V-1 AND V-2, REQUIRES BACKGROUND CHECKS CF GUARD FORCE PERSONNEL TO PE PERFORFED BY THE GUARD SERVICE COMFANY. PY CONTRACT BETWEEN P GEE AND BURNS INTERNATIONAL SECURITY SERVICES, INC
., t. ACM GP OUNC CHE CKS ARE TC INCLUDE, BUT NOT LI"IT ED 10, C 81 M I N A L ~, DEPARTFENT OF POT 00 VEHICLES, AND PRIOR EMFLOYERS. CCNTRARY TO THESE REQUIREMENTS, DEFARTMENT CF PCTOR VEHICLES AND PRIOR IMPLOYMENT C Hf C n s .'[ R E NOT PERF0PPED AS PART CF THE BACkGROU i
ND CHECKS. ! SECTION VII STATES " DETAILED PROCECURES HAVE BEEN [ ....RCUTINE SECbRITY PROCEDURES ARE MAINTAINED IN VOLOME 1- ADMINISTRATIVE PROCEDURES." THE TABLE O F C ONTE NTS OF VCLUME I - ADMINISTRATIVE FPOCEDUFES IDLNTIFIED THE FOLLOWING PROCEDURES AS EEING CONT 4 0
Ig D1/31/65
- 766 OATA FOR DE V I A T ION-SEVER IT V LEVELS PAGE 2
() HUMBOLDT DAV-05000133 JAN le 1972-TO DEC 31, 1978 e REPORT FkOF- TC DEVIATION / NGFeER D A TE DATE SEVERITY TEXT 7506 C7227$ 080175 3 AINED THEREIN: (A) SELE CTION OF PLANT SECURITY F0 RCE PERSONNELi (8) SECURITY FORCE TRAINING PROGPAM g * (C) CONTROL OF FIREARFSi (D) LOCK AND NEY CONTRO L. CONTRARY TO THESE REQUIREMENTS THE DETAILED AN D REUTINE FECURITY PROCEDURES IDENTIFIED AROVE HAD NOT BEEN DEVELOFED. 7506 072275 080175 2 SECTION VI-1, REQUIRES ALL CONTRACT SECURITY GUARD S TU EE GIVEN A 40 HOUR TRAINING COUESE PRIOR TO A SSIGNMENT TO THE HUMbOLDT BAY PLANT. IN ADDITION TO INE INITIAL TPAINING. IN-SERVICE TRAINING IN SP ECIALI2ED AREAS AND REQUALIFICATION TRAINING IS RE QUIhED OF ALL GUARDS ASSIGNED TO THE PLANT. CONTR AdY TO THESE REGUIREPENTS CONTRACT GUARDS DID NOT RECEIbE 40 HCURS OF TRAINING PRIOR TO ASSIGNMENT T U SECURITY F0kCE DUTIES AT THE HUMBOLDT PAY PLANT. ThAINING RECORDS BEINC MAINTAINED DID NOT REFLEC T Ih-SERVICE OR REGUALIFICATION T R A I? LING. 7509 OY2775 08247S 2 CONTRARY TO 10 CFR 70.42 (C) AND (D), WHICH REQUIR E VLRIFICATION AND WPITTEN CERTIFICATION THAT TRAN SFEhEE'S LICENSE AUTHORIZED RECEIPT OF TFE TYPE, F i CRM AND CUANTITY OF SPECIAL NUCLEAR PATERIAL TO BE l TRANSFERRED, THE HUMBCLDT BAY POWER PLANT DID NOT HAVE IN ITS POSSESSION SUCH WRITTEN CERTIFICATION FDP THREE SHIPPENTS OF IRRADIATED FUEL RODS TO VA LLECITOS NUCLEAR LABORATORY BETWEEN MARCH 11, 1974 AND JUNE 30, 1975. 7510 101475 103075 2 CONTPARY TC THE REQUIREPENTS OF 10 CFP 20 101(A), THREE INDIVIOUALS RECEIVED EXFOSURES TO SADIATION IN EXCESS OF 1 1/4 REM. THE REQUIREMENTS CF 10 CF F 20.10146) WERE NOT SATISFIED FRIOR.TO THE EXPOSU RL. 76C2 031376 031276 2 CONTRARY TO YOUR SECURITY PLAN, SECTION VII, AND Y OUP DETAILED SECURITY PROCEDURES, THE SECURITY ALA RM STATION IN THE REACTOR CONTROL ROOM DID NOT FUL FILL ITS FUNCTION AS A REDUNDANT BACKUP TO THE ALA RM STATION AT THE MAIN GATE WHEN TESTED DY THE INS
\
PECTORS ON MARCH 11, 1976 AT 1553 HOURS. THE CONT ROL ROOM PERSONNEL DID NOT REACT TO THE APPARENT I NACTICN OF THE GUARD FORCE WHEN SELECTED PERIMETER ALARPS WERE DELIBERATELY TRIPPED. CONIRARY TO YOUP SECURITY PLAN, SECTION IV, PARAGR APH B.3, THE FERIMETER INTRUSION DETECTION WAS NOT
C1/31/85 ,
=
766 DATA FDR' DEVIATION. SEVERITY LEVELS PAGE 3 ED HUMEOLDT RAY-03000133 JAN 1, 1972 TG CEC 31e 1978 () -__..............--... ---___.......---........ _______--................ --....--..__.---------_---.__.................-_........ REPCFT FbJP TC OLVIATION/ NUPEES DATE DATE SCVERITY TEXT q .-__.........--........----...........-------.................---.......................----..-......-----..-...................-- 7( cr 03I076 03127h 2 INSTALLED TO COVER THE ENTIRE FENCE PEPIMETEP IP: CUCH A MANNER AT TO DETECT ANYONE WHO CROSSES THE
- s. FENCE PERIMETER AND MOVE S INTO THE PROTECTE AREA.
THEINSPECTORS OBSERVED THAT THE DETECTION DEVICES HAD EEEN INSTALLED WELL INDISE OF THE EAST AND NO RTHLAST PORTION CF THL PERIMETER AT A DISTANCE. IN SOME CASES, OF AFEROXIFATELY 50 YARDS. CONTRARY TO YOUR SEC. PLAN, SECT. III, PARA. E, PR OCEDUFES, & TOUR MEMO DATED 3.5.76 (RE A TEMP. FEA SURF FOR ADCITICNAL PARKINGI, YOUR DETAILED ACCESS CONTROLS FCR GENERAL CONSTRUCTION FERSONNEL WERE NOT BEING FOLLOWED. THE INSFECTORS OBSERVED ON 3/ 11 L12/76: 1) AFP. 40 VEHICLES WERE- PERMITTED 10 P ASS TFROUGH THE PROTECTED AREA & WERE NOT UNDER CD NSTANT SURVEILLANCEt 2) PASSENGERS, OTHER THAN THE DRIVER, WERE PERMITTED IN THOSE VEHICLESI 31 THE SEARCH CONDUCTED AT GATE A 5 ON THE MORN OF 3/12/7 6 WAS INEFFECTIVE. THE GUARD CCFPLETED SEARCH IN 3-5 SECCNDS AND HELD THE HAND-HELD PETAL SCANNER A T A DISTANCE GREATER THAN IT COULD DETECT PETAL OB JECTSi 43 H A NDC AR R IE D ITEMS WERE NOT INSFECTEDI 53 VENICLE SEARCHES WERE NOT CONDUCTED, NOR HAD A FR EQUENCY FOR SEARCH bEEN ESTABLISHED. CONTR AR Y TO YOUR SECUR IT Y PLAN, SECT. III, PARA. A
& L, AND VCUR DETAILED PROCEDURES, ACCESS CONTROL e WIRE P.01 BEING FOLLOWED: 1) ON 3/11/76 AT APPROX
. Oh23.HCURS, A LINEN SUPPLY TPUCN AND DRIVER WERE ADMITTED TO THE PROTECTED AREA. THE DRIVER WAS B ADGEC WITH A RED-RED BADGE hEQUIRING ESCCRT AT ALL TIFES. THE DRIVER / TRUCK WAS NOT ESCORTED NOR WAS IT SEARCHED
- 2) ON THE MORNING OF 3/11/76, AFPROX
. 60 EMPLOYEES DEPARTED THE PROTECTED AREA WITH TH CIR PICTURE BADGES TO ATTEND A TRAINING CLASS. TH E BADGES 6ERE NOT SU R R E P'DE R E D AT TPE MAIF GATE AS FEGbIkED. FURTHER, UPON RETURN APPROXIMATELY TWO HOU6S LATER, THEY WERE NOT SEARCHEDi AND 3) ON 3/1 1/7L, AT APPROX. 0415 HOURS, THE INSPECTORS WERE N CT FEQUIRED TO IDENTIFY THEMSELVES TO A GUARD PRIO R Tb GRANTING ACCESS TO THE RLSTRICTED AREA.
7tC6 0*2676 052776 E CCNTRARY TO 10 CFR 50, APPENDIX B, CRITERICN VIII, PGEE CUALITY ASSURANCE MANUAL FOR OPERATIONS PROCE OURL NO. 3.4 AND PGLE ADMINISTRATIVE PROCEDURE NO. D-501, A SAFETY RELATED MOTOR CONTACTOP FOR TPE M AIN STEAM ISOLATION VALVE WAS FOUND IN STORAGE WIT HOUTA TAG IDENTIFYING THE STATUS OF THE CONTACTOR s k
an , 01/31/e5 706 DATA FOR DEVIATION-SEVERITY LEVELS PT.GE'O HUMBCLDT eAY.05C09:33
.JAN 1, 1972 TO DEC 31, 1978 RLPSRT FRC* TD CEVIATION/
NUSPEG DATE DATL SE VERITY TEXT 10C6 04Ee76 052776 2 AS "NOLL", " REJECT", CR
- ACCEPTED".
16C6 042e76 052776 3 CONTPARY TO 10 CFP SC, APPENDIX P, CRITERION WVII AND PGLE GUALITY ASSURANCE MANUAL FOR OFERATIONS PROCEDURE NO. 71, ADMINISTRATIVE PROCEDURE NO. E
-1, "REGUIRfFENTS FOR RETENTION AND ENTENDED STORA GL ;F OPERATION PHASE AACTIVITY RECORDS," HAD t.0T EEEN REVIEWED BY THE FLANT STAFF REVIEW COMMITTEE (P!RC) CP IMPLEMENTED BY THE PLANT STAFF.
70?0 74?t76 05 776 2 CONTRARY TO 10 CFR 50, APPENDIN R, CRITERI0N V, PG , SE CUALITY ASSURANCE PA*'UAL FCR CPERATIONS PROCEDU RE NO. 4.6, AND ADMINISTRATIVE PROCEDURE NO. F-101
, CFERATING LOGS WERE NOT WRITTEN AS REQUIRED. TH E FCLLOWING IS AN EXAMPLE. DURING THE FIRST TEN D AYS CF APRIL 1976, THE SHIFT FOREMEN FAILED TO SIG N THE LCG FCLLOWINC THEIR SHIFT ON 13 OCCASICNS OU T Cf A TOTAL OF 30 SHIFTS.
CONIRARY TO 10 CFR 50, AFFENDIN B, CRITERION XV, P GEE QUALITY ASSURANCE PANUAL FOR OPERATIONS PRCCED URE NO. 81, AND EUPPLEMENT NO. 2 TC ADMINISTRATIV E PROCEOURE NO. D-400, NONCONFORMANCE REPORTS WERE NOT bRITTEN ON PERMANENTLY INSTALLED *0N-LINE " ME , ASUh!NG EQUIRME'T FOUND OUT OF CALIeRATION. EXAMP LES ANE (1) CORE SDRAY FLOW SWITCH, FS-2536, CALIB RATED APRIs 5, 19763 AND (2) THE CONDENSATE DEMINE RALIZER EFFLUENT CONCUCTIVITY INDICATOR, CI-6251, CALIBdATED APRIL 12, 1976. CONTRARY T3 10 CFR 50, APPENDIX P, CRITERION V, PG , EE wuALITY ASSURANCE MANUAL FOR OPERATIONS PROCEDU RE t-0. 9.1, AND ADMINISTRATIVE PROCEDURE NO. C-2, REPvRT FORM 23*% WERE INCOPRECTLY FJLLED OUT. THE FOLLOWING IS AN EX AMPLE . FORP 23 NO. 306 76, DAT EO APRIL 1, 1976. CONCEPNS A REACTCR SHUTDOWN COOL ING SYSTEM RELIEF VALVE WHICH LEAKED DUE TO THE GU , IDE STEM BEING FROZEN TO THE GUIDE. NO PPICRITY W AS CInCLED. THE BLANK LABELED "QA CLASS" WAS INCOR RECTLY MARNED "N/A", AND THE BLANN' L APELf D "#EPORT
, ED CLEARED BY" HAD NOT HEEN SIGNED PY THE MAINTENA NCE FCREMAN.
, 7616 C9Cb76 091076 3 CONTRARY TO 10 CFR 50, APFENDIN P, CRITEPION IX, T
-HL WISMER AN[ BECFLP QUALITY ASSURANCE MANUAL, SEC TION IN, FARAGRAPH 3.3.4, AND THE WISMER AND BECKE
, R LIQUID PENETR ANT PROCEDURE No. 3500-500, THE LIO UID PENETRANT ENAMINATION OF THE WELO ON THE REPLA e
O
O C1/31/e5 7f6 DATA F OR CEVIATION-SEVERITY LEVELS PAGE S () JAN 1, HU:BOLDT BAY-03000133 1972 TO DEC 31e'197R # c) REPORY FROF 7? OEVIATION/ NUMfLk LATE DATE StVEFITY TEXT c) ..._____.________________..__._______________.___..._________...._____.__.___.......____.._______. ...._______....._________..___. 761C 090676 081076 3 CEPENT SECTICN nF THE CCRE SPRAY LIFE WAS CONCUCTE D BY AN ENAPINER WHO WAS NOT L O P.0 E P CERTIFIEC. am CONTRARY TO 10 CFR 50, APPENDIX B, CRITERION NVII, THE WISMER AND BECKER OUALITY ASSUPANCE MANUAL, S ECTION IX. FARAGRAPH 3.3.4, AND WISMER AND BECNER FROCEDURES NOS. 3500-300 (REV. 1) AND 3500-500 (RE V. 2), THE FECUIRED VISUAL ExAPINATION OF THE WELD 2 ON THE EPERCENCY C0fDENSER SUPPORT AND THE LIQUID PENETRANT EXAMINATION CF THE WELD CN THE REFLACEM ENT SECTION CF THE CORE SPRAY LINE WERE NOT DOCUME NTED AS HEGUIRED. 7613 049776 C91*76 i YCUb APFROVED SECURITY PLAN, SECTION II, PARAGRAPH C. STATES IN PART *THE FENCE SURROUNDING THE POWE 4 RUILLING AkD UNIT 3 CONTRDLLED AREA AND THE LOCK ED ADMINISTRATION EUILDING CONSTITUTES A DHYSICAL PARRIER AS CEFINED IN' 10 CFR 73.2(F)1.* CONTRARY TO THE ABOVE, IT WAS CBEERVED ON SEPTEMeFR 8, 1976 THAT A PORTION OF THE FENCE FOR UNIT 3 HAD BEEN R EM0wED AND A WOODEb GATE / DOOR CONSTRUCTED OF 2 X 4
'S AND COVERED WITH 5/8 INCH PLYWOOD HAD BEEN SUBS TITUTED. THIS CID NOT CONSTITUTE A SUBSTANTIAL BA PRIER AS DEFINED IN 10 C F R 73.?tF)1.
CONThARY TO YOUP SECURITY PLAN, SECTION VII, AND Y CUR DETAILEC SECURITY FROCEDURES, THE SECONDARY AL AR" STATION (SASI IN THE REACTOR CONTROL ROOM DID r.0T FULFILL ITS FUNCTION AS A REDUNDANT BACKUP TO ! THE ALARM STATION ON 9/E/76. IT WAS OBSERVED AT A FPR0x!MATELY 7:05 ANr. 7:30 A.P. CN o/8/76 THAT TWO ALARPS FRCP ZONE D 6ERE RECEIVED AT THE PRIPARY C ENTFAL ALARP STATICN (PCAS) AND bERE NOT INVESTIGA TED FY THE SECUPITY FORCE. THE SAS TOOK NO ACTION ON THE INACTION OF THE SECURITY FORCE . THIS IS A REFEAT ITEP OF NCNCCMPLIANCE. (REFERENCE INFRACT I O P. O, OF LETTER DATED APRIL 2, 197f.) YOUR APPROVED SECURITY PLAN, SECTION VII STATES "O ETAILEC FROCEDURES HAVE REEN DEVELOPEC FCR USE IN VARIOUS ROUTINE AND EPERGENCY SECURITY SITUATIONS. FHYSIC AL SECbRITY PLAN IMPLEPENTING PFOCEDURE N
- 2. 5-2. SUSPECTED CR ACTUAL INTRUSION PROCEDURE, L ISTS AS AN ABNORMAL CONDITION - ONE ALARM ON THE P ERIFETER (PARAGFAPH A.1.A) AND AS AN EPERGENCY CON DITION - PORE THA N ONE AL ARM IN A SHCRT PERIOD OF TIML (MINUTES) THAT INDICATES A SUSPICICUS PATTERN (PARAGRAFH A.2.A). THAT SAPE PROCEDURE, PARAGRAP H C. REGUIRES OFFICEFS TO RESPONO TO ALL ALARMS.
Y. t_
01/31/65 ,
- 766 CATA FOR DEVIATION-SEVERITY trVELS PA![ 6
_, HUMPOLDT BAY-05000133 JAN to 1972 TO DEC 31, 197R PEP 06T FFCP TO CEVIATT0h/ NUPlip D r. T L LATE St VLP IT Y TEAT
.7613 On0776 C91376 2 CCNTRAhY TO THE ABOVE, IT WAS OBSERVED ON 9/P/76, AT APPRCXIMATELY 7:25 AND 7:30 A.M., TWO ALARMS FR OM 20NF D WEPE RECEIVED AT THE PRIMARY CENTRAL ALA RP STATION. BCTH ALANPS WERE SILENCED A P.D R E S E T W ITH0UT INVESTIGATION BY THE SECURITY FORCE.
YOUR APFROVED SECURITY PLAN SECTION 1, STATES IN P ART (REFERRIhG TO INTRUSION LEVICES) " SELECTED DEV ICES MAY.PE PEPCVED FRC' SEPVICE DURING PEPIODS WH LRE PERSCNNEL ARE WO F. K IN G IN THE AREA PROTECTED AN D CAN PAINTAIN VISUAL SURVEILLANCE." SUPPLEMENT N
- 0. 1 TO NUCLEAR PLANT ACPINISTRATIVE PROCEDURE NO.
1-6, ACCESS CONTPOL TO PLANT AFEAS, PARAGRAPH B.7
.1, STATES I P: PART "WHEN A ZONE IS IN " ACCESS" (DU L TC bCRK Ik THE AREA OP DUE TO AN INOPEPABLE LINK
) TtE 20NE SHOULD RECEIVE INCREASED SURVEILLANCE."
CLNTRARY TO THE AHCVE, THE FOLLOWING INTRUSION Z CNES CF THE PERIMETER W[RE OBSERVED TO PE IN AN AC CESS PODE WITHOUT COMPEFSATORY SECURITY PEASURES T C PROVIbE VISUAL SURVEILLANCE: A) 9/7/76, 5-5:30 F.M., ZONES C.D.E.F,G3 B) 9/8/7f, 7-7:30 A.M., 20 NES C,D,E,F; A P:D C) 9/6/76, 1:10-1:30 P.M., ZONE S LH, N. YOUR APPRCVED $[CURITY PLAN, SECTION II, PAPAGRAPH C. STATES IN PART, "THf INTRUSION ALARP SYSTEM WH ICh IS DISCUSSED IN SECTION IV 0F THES PLAN COMFLI ES WITH THE FEGUIREPENTS OF 10 CFR 73.2(1)," SECT ION IV, FARAGRAPH C.2 STATES IN PART " PERIMETER SE CURITY SURVEILLANCE DEVICED (OMNI-SPECTPA) ARE INS TALLED AROUND THE INSIEE OF THE PERIPETLp 0F THE I
, P:NE6MOST SECURITY FENCE. THESE DEVICES COVER THE ENTIRE INNLh"0SE SECURITY AREA EACEPT FOR THE ENTR ANCES CF TPE ADPINISTRATION BUILDING IN SUCH A PAN , NER AS TO DETECT ANYONE (OR T HI Nr-) WHO CROSSES THE FEPIPETER AND POVES INTO THE INNEP' YARD AREA." C ONTEARY TC THE AROVE, IT WAS OhSERVED ON SEPTEMBER E, 1976 THAT A NEW TEPPORARY BUILDING HAD BEEN EPE CTED IN THE SOUTHEASTERN PORTION OF THE CCNTROLLED ARLA, AND THAT AREA WAS NOT PROTECTED BY PEPIPETE , , R SLCURITY SORVEILLANCE DEVICES (0Phl-SPECTRA). 8 ECAbSE OF THAT CHANGE IT IS POSSIBLE TO CUT OR CLI PP ThL FENCE AND ENTER THE INNER YARD AREA, VIA TH , E R UDF CF THE NEW PUILDING, WITHOU CETECTION.
7616 101976 102176 2 CONIPARY 10 10 CFR 50 FARAGRAPH 54(I-1), PG8E LETT
, ERS CONCEFNING THE LICENSE OPERATOR RETPAINING PRO GPA" CATED CECEMBER 14, 1973 AND MARCH 15, 1974, A e
6 e
. . _ . w x q
C) . 01/31/Ff 7(E DATA FOR CIVIA**rN. SEVERITY LEVELS FAGE 7 () HUEE0LUT EAV-03000133 JAN 1, 1072 TO DEC 31, I?7R () .......___......__________________........____......__________...__.....______.._______...____ ..___.._____................... _.. REPCbT '5RF T1 DEVIATION # NUMrEn EATE DATE FEVEPITY TEXT . c) _._____....______ ....____...__________....._____.... __.. ._____........__......._______.....___......___.___.._____.__......___. 7616 101a76- 101270 2 ND ADMINISTEATIVE FRCCEDURE NO. D-101, "NRC LICENS ED EPERATCR RETRAINING PROGRAM," THE ANNUAL ORAL E NAMINATION bA$ NOT ADPINISTERED IN 1974. CONTRARY TO 10 CFR 50 PARAGRAPH E4(I-1), PGEE LETT FRS CCNCERNING THE LICEwSE OPERATOR RETRAINING PRO GRAP DATED CECEPHER 14, 1973 AND PAkCP 15, 1874, A r.D ADMINISTRATIVE PROCEDURE NO. P-101. "PRC LICE NS ED CPERAT0k RETRAINING PRCGRAP," QUAkTERLY ENAMINA TIONS FCR LICENSED OPE P ATORS WERE NOT GIVEN AT THE SDECIFIED FREQUENCY. 7010 101976 102 76 3 CONTRARY TO 10 CFR 50 PARAGRAPH 5441-1), PGEE LETT ERS CONCLRNING THE LICENSE OPERATOR RETRAINING PRO CR A F' CATED DECE*3ER 14, 1973 AND PARCH 15, 1974, A F.D ADFINISTRATIVL PROCEDURE NO. B-101 SUPPLEMENT N G. 2, " RETRAINING - FLANT DESIGN, PRCCEDURES AND F ACILITY LICENSE CHANGES." THE LICENSEE ALLOWED SUC H CbAr.GES TO REPAIN UNREAD BY LICENSED CPERATORS F GR LP TO SI) MONTHS. 05000133 761E 2A DAP CONTRARY TC 10 CFc 50 PARAGRAPH 54(I-1), FG&E LETT ERS CONCERNING THE LICENSE OPERATOR RETRAINING PRO GRAf DA TED LECErdER 14, 1973 AND PARCH 15, 1974 A , ND ADPINISTFATIVE FROCEDURE NO. B-101, "NRC LICENS LD (PERATOR RETRAIPING FROGRAF," INDIVIDUALS WHG W ERE SuePISEL TO HAVE FAILED THE ANNUAL WRITTE N OPE RAT;R ERAPINATION WERE P;07 REMOVED FROM THEIR PEGU LAR SHIFT OR PROVICFD WITH ADDITIONAL SUPERVISION. 770; 012677 02177 2 CONTRARY TC 10 CFR 20.1G148)(1), bHICH LIPITS QUAR TLRLY ENFOSURES TO A MADIMUM OF 3 RLF, AN EPPLOYFE RELEIVEC AN EXPO!URE CF 3.2 REr, AS SH0bN BY b!S FILP EAUGE, DURING THE FOURTH GUARTER OF 1976. 1703 C;2977 03f;77 2 10 CFP 50, APPENDIN H, CRITERION V PECUIRES THAT A CTIt! TIES AFFECTING CUALITY BE ACCCFFLISHED WITH I NSTPUCTIONS. THE PGLE CA MANUAL PROCEDURE 4.1 REQ UIRES TbAT THE PLANT SUPERINTENDENT BE RESPONSIBLE F0H FRLPARATION AND APPROVAL OF PROCEDURES FOR TH E RiUTINE AND SFECIAL PAINTENANCE OF COPPONENTS AN E' TbAT SUCH PRCCEDURES SHALL INCLUDE PROVISIONS FO R INSFECTION OF WGFN. CCNTRARY TO THESE REGUIREPE NTS THE INSTPUMENTS IN TWO CABINETS IN THE CONTROL ROOM WLEE REMOVED WITHCUT THE EXISTENCE CF PROCED URES. n
G1/31/6E 766 DATA FOR DE V I AT ION-SE VER I TY LEVELS ~ - PACE 6
, HUMBOLDT E, AY.05000133 - ,I JAN 1, 1972 TO DEC 31, 1978 Ft&CFT FhSF Ta LEVIATION/
$[VER!TY Nd*fE9 LA?E DATE TENT 77C4 C3:777 C40577 5 CONIRARY TO 10 CF R 2C.401(B), THERE'WERE NO PECORD S OF THE FESULTS OF THE. SURVEY FOR CONTAFINATION M
, ADE IN CONNECTION WITH TbE RECEIPT OF Ni W FUEL - ON APRIL 13, 1976.
7 Tt 4 t'0777 C40577 2 CONTRARY TO 10 CFP 20.101(B)(1), AN INDIVIDUAL WOR MING IN THE. CONTROLLED APEAS OF THE PLANT RECEIVED A TOTAL EXPOSURE OF 3.010 RfrS DURING TFE PEFICD JANUAFY 15 THROUGH FEERUARY 4, 1977, AND ANOTHER I NDIVIDUAL IN THE CONTROLLED AREAS OF THE PLANT REC EIVED A TOTAL EXPOSURE OF 3.330 REMS DURING THE PE
, EIOD FEBRUAP.Y 7 THROUGH MAOCH 8, 1977.
CGNTRARY TO 10 CFR 20.2CI(P), EVALUATIONS WE9E NOT ADEGLATE TO ASSURE COFFLIANCE WITH 10 CFR 20.10It F)(1), " EXPOSURE CF INDIVIDUALS TO FADIATION IN RE STPICTED AREAS," A REGULATION THAT LIMITS THE CALE ADAP CUARTERLY EXP0eURE TO A MANIMUM OF THREE REMS ,
, . EPLCIFICALLY, ALL DAILY DDSIMETEP READINGS FOR THE SECOND INDIVIDUAL kHO WAS OVFREXPOSED WERE P.0T ALL AVAILAPLE AND THEREFORE WERE NOT UTILIZED IN THE EVALUATION. THIS PF EVENTED AN ADEQUATE EVALUA TION OF HIS ACCttMULATIVL EXPOSURE SO THAT HE COULD PE REMOVED FROM ACTIVITIES INVOLVING EXPOSURE TO RADIATICN FRICR TC ENCEEDING THE LIMIT.
7707 050577 051177 3 CONTRARY TO TECHNICAL SPECIFICATION IX.I.2.P.(3),
, THE FAILURE TO CONDUCT THE MONTHLY RLFUELING BUILD ING ISOLATION MONITOR TEST, OTP.8C, IN DECEMBER 19 -
76, AS REQUIRED BY TECHNICAL SPECIFICATION VII.O.5
, WAS NOT REPORTED TO TFE NRC.
7712 3E1677 CtIE77 2 00NTR AR Y TO 10 CFR SD, FARAGRAPH 54(I.1), PG&E LET
, TERS TO THE COMMISSION CONCERNING THE LICENSED OFE RATCR REQU ALIFICATION PROGR AM DATED DECEPHER 14, 1 973 AND MARCH 15, 1974, AND ADMINISTPATIVE PROCEDU , PE NC. 0 101, "NRC LICENSED OFERATOR RETRAINING PR OGRAM6" GUARTERLY Ex AMIN ATIONS F OR LICENSED OPERAT OPS HAVL NOT BEEN GIVEN AT THE SF ECIFIED F RECUE*JCY , IN 1977.
CON 1RARY TO 10 CFR 50, PARAGRAPH 54(I-1), PGEE LET TERS TO THE COP"!SSION CONCERNING THE LICEhSE CPER
, AT0h REGUALIFICATION PROGRAM DATED DECEMBER 14, 19 73 AND MARCH 15, 1974, AND ADMINISTRATIVE PROCEDUR E NO. B-101, "NRC LICENSED OPERATOR RETRAINING PRO , GRAMi" INDIVIDUALS SCORING LESS THAN 70 PERCENT ON SECTIONS OF THE 1975 AND 1976 ANNUAL WRITTEN ENAM e
e
i 01/31/c5 766 DATA FOR DEVIATION-SEVERITY LEVELS PAGE 9. HuvbCLDT 6AY.05000133 JAN I, 1972 TO CEC 31, 1978 F(F M T F.:P T; CEVIATICN/ Su'LEp CATE DATE SEVERITY TEXT 7712 0Fle77 OP1677 2 INATIONS CID P.OT RECEIVE REMEDIAL TRAINING. CCNTR aR Y TC 10 CFR 50, PARAGRAPH 54(I-1), P080 LET TERE'TO TbE COMPISSICn CCNCERNING THE LICENSED OPE RATCR REGUALIFICATION FROGnAM DATED DECEPBER 14, 1 973 AND FARCH 15, 1974, AND ALMINISTRATIVE FROCEDU FE is 0. B-101. SUPFLEPENT NO. 3, " RET *AINING-ARNORM AL AND ErtRCENCY PROCECURES8" TWO 0FAL DEPCNSTRATI ON EAAMINATICNS WERE NOT G IV E r: TO EACH LICENSFD OP ERATOL IN 1976. NINE CF 14 LICENSED OPERATCRS REC EIVED ONLY ONE SUCH EXAMINATIONI FIbt LICENSED OPE RATCRS RECEIVED NONE. CONTRARY TO 10 CF R 50, FARAGRAPH 54(I-1), PGer LET TER5 TO THE COMPISSICN CONCERNING THE LICENSED CPE RATOR RECOALIFICATION PROGRAM DATED DECEPDER 14, 1 973 AND NARCH 15, 1974, ADMINISTRATIVE PRCCECUPE N
- 0. E-101, "NFC LICf NSED OPERATCP RETRAINING PRCGRA
'i" AND ADMINISTR ATIVE PRCCEDURE E-101, 'UPPLEMENT NO. 1. " RETRAINING REALTIVITY MANIFULATIONSi" ONE SENIOR LICENSED CPERATOR (SDP-193-5) DID NOT TAME THE 1975 OR 1976 A NP!U A L WRITTEN ERAFINATION, A f40 DID NOT MANIFULATE PLANT CONTROLS OF DIRECT THE AC TIVITILS CF INDIVIEUALS DURING *EACTIVITY CCNTRCL FANIPULATIONS IN 1975, 1*76, OR TO DATE IN 1977.
7715 It?$77 100677 2 CONTRARY TO 10 CFR 20.201(b), PERIODIC SbnVEvS OF THE EFFLLENTS BEING RELEASED TO TbE ATFCEFHERE VIA THE RC0F VENTS FCR THE HOT PACHINE SHOP, NOT LABO FATCRV, LAukuRY CLOTHES DRYER AND LIGUID cACWASTE TANG 5 MAO NOT BEEN FADE SINCE 1974 TO AS?URE THAT SUCN RELEASES btRE WITHIN THE LIFITS CF 10 CFR 20. 100. SURVEY PEANS "AN EVALUATIDr. CF THE RADIATION hAiARDS INCIDENT TO THE... RELEASE.. 0F FADIDACTIV E FATERIALS...UCCER A SPELIFIC SET OF CDPDITIONS. 7715 1c0377 10 0t 77 3 CONTRARY TC PD.203(F)(1), A PLYWOOD BOX, LOCATED I N inE WASTE STORAGE AREA, CONTAINING RADICACTIVC M ATEEIAL THAT CFEATED RADIATION LEVELS UP YO leC PR
/HR AT Aucui Ot4L (1) INCH FROM TbE* SURFACE OF THE BASTE HAD N3 LAEEL WHEN OBSERVED ON OCTOBER 5, 197 7.
7FC9 to/679 37C67e ? CONIRARY TO TECHNICAL SPECIFICATION IX.K. "RADIATI ON FROTECTION P90 GRAM," AND PGSE RADIATION CCNTRCL STANDAR0 f.3.A. A NCMINAL 30-MILLICURIL CESIUM-13 7 SEALED SCURCE WAS NCT LEAK TESTED DURING THE CAL ENDAR YEAP 1977. THE STANDARD REQUIRES THAT SUCH e e
_,__,:__ ._ , a . C1/31/t5 17F.6 DATA FOR DEVIATIO2-SEVEQITV LEVELS PEGE 10, ,. HUIBOLLT GAY-05000133-
-JAN I, 1972 TO DEC 31, 1978 REPORT FEC'~ TC DEVIATICN/
NLPcER PATE DATE- SEVERITY TEXT 7eD9 062F 7e 070678 2 SOUG.CES CONTAINING MORE THAN 100 PIC#0 CURIES OF AC TIVITY TO BE LEAM TESTED AT INTERVALS NOT TO EXCEE D SIX MONTHS. THE SOURCE HAD BEEN LEAM TESTED TWI CE IN 1976 AND WAS LEAK TESTED ON JANUARY 18, 1978
. ALL OF THE LEAK TESTS ON THIS SOURCE HAVE SHOWN REPOVABLE ACTIVITY WAS LESS THAN 0.005 FICROCURIE S.
781C 071178 071578 3 CuNTRAFY 70 TECHNICAL 5FECIFICATION IX.D.2.I, THE CENERAL OFFICE NUCLEAR PLAhT REVIEW AND AUDIT COMM ITTLE DID NOT RECORD ALL OF THEIR REQUIRED ACTIVIT IES INTO WRITTEN PINui[s OR rep 0RTS. e Ok , 6
$ :h ,
/ $ ff#v t
- M % UNITED STATES
! 4- f ,e NUCLEAR REGULATORY COMMISSION 2 d' ... I wa:HinsTow. c. c.20sss October 27, 1983 Docket.No. 50-133 -
LS05-83-10-055 MEMDRANDUM FOR: Dennis M. Crutchfield, Chief Operating Reactors Branch #5, DL FROM: Peter B.' Erickson, Project Manager Operating Reactors Branch #5, DL i
SUBJECT:
HUMBOLDT BAY PLANT DECOP91ISSIONING - TRIP REPORT . The purpose of this trip was to tour the plant site and discuss the planned decomissioning of the Humboldt Ba Nuclear Plant with Region V personnel and Pacific Gas and Electric (PG& . On October 17, 1983 I visited the NRC Region V office to discuss Humboldt itay dece rnissioning with Frank Wenslawski, Phill' Morrill and Jim Hanchett.
. We aiscussac Ine status qf Ina plant and tne present and ;1ar.nec i.RC Kules and Guides on decomissioning.
On October 18 I visited the Humboldt Bay plant accompanied by Jim Hanchett Public Affairs Region V and Bili Pearson, CEBR, RES. Following a tour of the plant we discussed Humboldt Bay decommissionings Enclosure 1 is the agenda of that meeting. A suggested outline for the Humboldt Bay Plant Decommissioning
- Plan (Enclosure 2) was provided to PG8E personnel. PG&E indicated that their decommissioning plan and an application for a possession - only license is scheduled for submittal about March 1984. PG&E is now preparing the fuel storage pool for transfer of the fuel from the reactor vessel. Fuel i unloading is scheduled to start in January 1984. PG&E intends to place the Humboldt Bay plant in a SAFSTOR mode for about 30 years after which the -
residual radioactive material would be removed and transferred te an authorized burial ground. The spent fuel will be transferred from the spent fuel pool to an authorized high level repository when one becomes available. Peter B. Erickson, Project Manager Operating Reactors Branch f5 - Division of Licensing k l .. i . poo7W U PP 26, - 3
7 8 i*. - Mr. J. O. Schuyler October 2:', 'J23 Pacific Gas and Electric Company _ Humboldt Bay Power Plant, Unit No. 3
- ccc
Mr. James Hanchett Michael R. Sherwood, Esq. . Public Information Officer Sierra Club Legal Defense
- Region V - IE .
Fund, Inc. U. S. Nuclear Regulatory Commission 2044 Fillmore Street 1990 N. California Boulevard San Francisco, California 94115 Walnut Creek, California 94596 Linda J. Brown, Esquire
- f. Mr. Eric W. Hedlund Donohew, Jones, Brown & Clifford
, Humboldt County Board of Supervisors ~ 100 Van Ness Avenue,19th Floor County Courthouse San Francisco, California 94102 j 825 Fifth Street ' - , Eureka, California 95501 Dr. Perry Aminoto i Department of Conservation Bruce Norten, Esq. . Oivision of Mines & Geology l 3216 N. Third Street, Suite 202 1416 9th Street, Room 1341 l Phoenix, Arizona 85012 . . Sacramento, California 95514 (_ California Department of Health Friends of the Earth i ATTN: Chief Environnental '
- ATTN: Andrew Bal M n Radiation Control Unit 124 Spear Street Radiological Health Section San Francf sco, California 94105 714 P Street, Road 498 Sacramento, California 95814 Mr. Joseph 0. Ward, Chief
. Radiological Health Branch U..S. Environmental Protection State Department of Health Services Agency 714 P Street, Office Building #8 l Region IX Office Sacramento, California 95814 Regional Radiation Representative .
215 Freement Street San Francisco, California 94101 - Rtbert H. Engelken . . Regional Administrator, Region V U. S. Nuclear Regulatory Commission 1990 N. California Blvd., Suite 202 , i Walnut Creek, C'alifornia 94596 e ( .. I t N
\
' ~
~
*i .__ - _ ,. . _ . _ . f;m _
*. - n . * ~
Ag:nda for PGandE/E.TC Tcchnical Me: ting ENCLOSURE'1 r, Regarding Hu:fooldt.Eay Unit 3 Decom=issioning Eureka. California. Cetober 18, 1083 I. Introduction of PGandE Pa*ticirants (J. O. Schuvier) EC MuE P. 3. Erickson, ORB A5 J. O. Schuyler, (Jim) - VP-NPG V. R. Pearspn, CEBR E. D. Weeks , (Ed) - Mgr. - B3PP J. Flandiett, Region V R. T. Nelson, (Terry) - Proj. Manager J. H. Raggio, (Jay) - NPO-General Office ' G. C. Wu, (George) - Licensing-General Office II. Purpose . The purpose of this meeting is to accomplish the following: Advise the NRC on how PGandE plans to proceed with the decommissioning of Humboldt Unit 3 Establish functional contacts between the,NRC and PGandE. Discuss applicable regulatory guidance.
~
Identify as early as possible r .y constraints or hold / approval points the NRC may vish to apply to our program. III. Plar t To.:r IV. g :rittien of Curr'ent Plant Status (E:7.?eeks) Operating License (brief description of current requirements). Plant =anpower ud staffing ~ levels s , , , V. Description of Planned Dece:nissioning Activities (RTNelson)
- Preparation for Custodial SAFSTOR.
- Applicable regulations and regulatory guidance.
- Storage / Disposal of Spent Fual.
- Status of the Unit during the dormancy period.
VI. Description and Schedule of Documents to be Submitted (RTNelson)
- Decommissioning Plan / Safety Analysis.
- Amendment for Possession Only License.
- Revised Technical Specifications.
VII. General Discussion of Areas Requiring Resolution with the CRC
- Schedule for Review and Approval of Documents.
. - Heed for an Environmental Assessment.
s - Security Requirer.ents.
- Plant Staff Requirements.
(, YIII. CRC Re=1rks .
- Status of Decommissioning Rulemmicing.
- Assessment of PGandE's Plans as Described.'
JERaggio(kT09):ry svW5t1VTD
l,.* *, * * * . Et: CLOSURE 2 TOPICAL OUTLINE FOR SUE *.ITTIM IhFORF.ATION F OR DiCO*..".15510.'. i hG M'. ".K D' S t. Y j The fc11owing is a suggested outline, witn explanatory notations, for submitting in' formation needed by the NRC staff on deconimissioning on Humboldt .- Bay n'uclear power reactor.
- 1. LEGAL AND FORMAL.INFORMATION .
1.1 Acolication 3 An application for a license amendment to initiate decommissioning should I be filed under sections 50.82 and/or 50.90. Connunications should be establishec under section 50.5(a). Three sianed originals and 10 copies of the apol'ication shocid be submitted. ~ , e . . 9.2 Technical Specificatio6s !l
- ..If the Final Decomissioning Plan is submitted with the Application, changes i- to the technical specifications may be included'i,6 fection 2.3.5 of the plan.
Othgrwise technical specification changes should be submitted under sections 50,59 and 50.90. 1.3. Environmental Impact Statement An Environmental Ic' pact Statement (EIS) may or may not be recuired under ' 10 CFR Part 51, section 51.5(b)(7). The licensee will be required to submit an environmental report (ER). To the extent practicable, the ER should be tritten using the guidelines in section 51.20(a) and (b). The ?:RC will write an envirenmental impact appraisal (EA). Basec on the EA, the NRC will determine whether or not an EIS should be prepared. If it is deter .ined that an EIS is not needed, the NRC will prepare and publish a ( - negative declaration. The EA, which forms the basis for any negative declaration, ' will be made publicly a,vailable. .. l
..m. a. _ m, _._ c_ _ . _ _ _ . _ _-
.* .-.z.. >. .: - - - + .. . . . .
s _ (
- 2. FINAL DECOM. FISSIONING PLAN 2.1 Sumary Cescriotion -
This section should contain a brief' description of the proposeo final decom-cissioning plan. Include such topics as selected decommissioning alternative, . final estimated cost, amount of available funds (including sources of outside financing if appropriate), ma'jor tasks and schecules (in particular the estimated date for completion of decommissioning), items subject to quality assurance, tasks that may be per.fonned by a contractor, and the final radiation surysy plan. 2.2 General Information $ 2.2.1 Decommissionine Alternative In this sectiori the licensee should briefly describe the decomissioning - alternative selected. * (
' 2.2.2,,Decommissionino Oroanization and Responsibilities
- In this section the licensee should identify key positions in the deconcis-sioning organization and describe their functions. The lines of authority up to th2 corporate level should be indicated. The person with ultimate onsite authority should be designated by position and name. The education, training, and experience recuirements shoud be described for positions that are important to '
j sa fety. 2.2.3 Trainino Procram 2.2.3.1 Trainino Procram Description This section shculd contain a description of the proposec training prograc, includipg contractor personnel as well as licensee employees. The description should include the scope of training in decontamination and other decommissioning actiyities, heal' h tphysics, and use and main,tenance of monitoring eouipment.
. . - - . _ _ . .= .--
i., . ( 2.2.2.2 Trainir.c Free a- A:-inistratter ene Recorcs
, The personnel responsible for maintair.ing the treir'n; program recor:s s . .
l (e.g., status of trained personnel, training of new employees, ref resher or 4
- upgrading). should be describec in this, section, i -
2.2.4 Quality Assurance In this section the licenses should describe the Quality Assurance (QA) - program to be established and execute'd during seconsissioning, and list the - items that will be subject to the QA program. The QA program should be
~
established at the earliest practical time consistent with the schedule for , accomplishing an activity or task.* Where some portion of the QA program has not been established at the time the Final Deconsnissioning Plan is submitted i l the der:rictie- should else orgvide a schedule for imelementation.
- ( !.2.5 Radiation Protection f -
2.2.5.1 Ensurino that Qccuoatibnal Radiation Exposures are As Low As Is Reasonably Achievable (ALARA). -
. This section shculd contain a description of' methods for occupational
~
' radiation protection. It should provide information on equipment, techniques, *-
and practices that will be employed by the licensee in meeting the standards for protection against radiation of 10 CFR Part 20, including ALARA. The management policy and organizational structure related to ensuring that
~
occupational radiation exposures are ALARA should be described. Describe the
'responsibilitieg and the activities of management personnel having responsi-bility fer raciatier ;rcte: tion anc mair.taining occupational exp sures A'.AFA.
~
Describe also how knowledge from previous deconmissioning reports and from the g available literature will be used to improve decommissioning designs and procedures.
- (^ ,
l
- An " activity" is considered an organized unit of work for accomplishing a '
specific function and may consist of several tasks. -A " task" is a specific work assignment or job. 3 -
. .- i .
* ^
2.2.5.2 Healte. Physics Procrar
, The aaminis.trative organization of the health' physics program shoulo be /
d2scribec. , The authority and responsibility of each position shoulo also oe / id2ntified. Tne criteria for selection of ecuipment anc instrumentation for / performing radiation and contamination surveys, area ra'diation monitoring, andv' . personnel monitoring should also be provided in this section. Describe the use,/ stcrage, calibration, testing, and maintenance .for these instruments. The policy,/ method's, frecuency, and procedures for conducting radiation surveys and personnel / . monitoring should also be described./ i 2.2.6 Centractor Assistance The licensee may choose to accomplish some or all decommissioning activities and tasks by using contractors. However, the responsibility for health and s'1fety during cecommissioning' rests with the licensee.
.. , For each contract
- ~
- describe the scope of work to be accomplished, the administrative control system l useq to ensure adeouate health and safety protection,
, and the relation of the contracted work 'to the schedule for other activities.
2.2.7 Cost Estimate and Fundino
, In this section the licensee should present a cost estimate for accomplishing desommissioning. This estimate should be based on conditions at the facility at the time the Final Decommissioning Plan is submitted. The cost estimate should spetifically ir[clude estimated costs of the tereination radiatien suney (see s";ction 3). The licensee should also show how sufficient funds will be made s
available to accomplish deconcissioning. Include, if a delayed deconcissioning l( alternative is s' elected, plans for perioote. reevaluation during safe-storage ' period. . , 4
t 2.3 Safety Analysis , ( - , 2. 3.1 Facility Descriotion 2.3.1.1 Facility Deeratine History Tne licensee should describe historical information on operational c:.currences that could adversely affect decommissioning safety. . Such things as spills or , releases that resulted in significant contamination, specific location of systems and eouipment that may contain high levels of radiation, and areas of the site i that may contain radioactive hot-spots should be described. This type of information can be obtained from facility records anc personnel familiar with the
- facility. .. .
j
- 2. 3.1. 2 Currer.t Radiolecical Status of Facility Radiation levels for systems, structures, and components should be estaoiisnec at tne time the. Final Decomissioning Plan is suomittec. It is I.( re:cgnized that at the time of submittal complete information may not be available for planning of activitie,.s Howev'er, to the extent practicable, sources of radiation that are the basis for radiation protection should be described.
nformation in this section should be updated as . additional radiation surveys are made. The description should tabulate sources by isotopic composition and j gamme ray energy groups, strength (curie content), and geometry. Sources of l radioactivity should be located on plant layout drawings. For all sources. l _ including activation product sources, the model(s) and parameters for calculating the source magnitudes should be previded. 2.3.2 Radioactive Waste Manaoement - [ - 2.3.2.1 Fuel Otsoosal i Used and spent fuel should be removed fror the pressure vessel and stored in ( the Spent Fuel Pool. U'ed s and spent fuel may be removed from the reactor to fuel storage under existing license and technical specifications prior to approval of 5 .
- -.n _- , - - - _ _ ...v.. .._.---, ~ w,,- ,, ,,-,----, -r n -wm,-ww_ ,_ .,y--m-,mwwn-
, - - w-n- w--w~
. ,. i \
- inal Decom-issioning Plan. Existing technical spe:1fications for the Spar.: Fuel Pool operations will remain in effe:t until changed by iicense amencment or approval of Final Decommissioning Plan.
. 2.3.2.2 Radioactive Waste Processing o+
The licensee should describe how contaminated gaseous, liquid, and solid radioactive wastes will be generated and the systems used for their treatment. Relate the discussion to radioactivity levels,' volumes of radioactive waste, '
' existing systems that will be retainec in an operation status, and systems that will be instal' led. Schedule (s) submittec. in section 2.3.3.3.should clearly indicate the avail' ability of these systems.
2.3.2.3 Radioactive Waste Disposal The O!r sFc:;11 cea;eir a descri-tien of the : cce:tes a.:: sys:6. s ;; sac fc-i handling, storing, and disposing of radioactive wastes. If radioactive wastes ( tra to be stored onsite, methods for containment and monitoring of the contain-ment should b,e explained. 2.353 Decommissioning Tasks and Schedules 1 , 2.3.3.1 Descriotion l l In this section the licensee should tabulate major decommissioning activities and tasks. Activities related to preparing the facility and site for safe storage should be described in detail.' Activities for keeping the facility and site in safe storage and for final decossissioning should be described to the extent l, they are known. - 2.3.3.2 Task Analyses j Descriptions and procedures for accomplishing major activities should be
, provided. A safety analysis should be included for activities and tasks that are important to safety. * *
\ ..
\\
n
., _ . ~ . . .. -- . - ~ - - ..-.... -.~.....a... .-- .- - . . . -- - - - .- - I' 2.3.3.3 Task Schedules For major activities, the relationship between activities anc tasks shcule be shown. Where pertinent, the schedules for accomplishing interrelated activi-ties and tasks should be delineated. Schedules or diagrams should clearly hndicate the estimated time for completion of decommissioning. .
( 2.3.4 Safeevards and Security A description and schedule of any propose' dchanges in the NRC approved physical security plan and when applicable the hRC approved material control I I and Accounting plan sh'ould be submitted in this section. g 2.3.5 Technical and Environmental Specifications l l Technical specifications for decommissioning will be derived from an l i e alysis c' the Ferlt." eat sa'p'y are envir:n=enta? arressre-t c' te::.cis:;i:-i. ; ( the facility. The analysis should lead to the conclusion that the health and
, . safety of the public'and deconmissioning personnel will be protected if all
- operations are performed within certain prescribed limits. These limits should-be defined and established by the licensee and reviewed and approved by NRC.
2.3.6 Accident Analyses A discussion of accidents that could occur during decommissioning should , be presented in this section. Sufficient detail should be included so that
~
j significant potential accidents will be revealed and analyzed.
- 3. TERMINATION RADIATION SURVEY PLAN
, . 3.1 Proposed Termination Radiation Survey Plan 3.1.1 Early Consicerations TMe, ultimate goal of a termination radiation plan is to provide the basis for verifying that the facility and. site meet radioactivity levels that permit l -
l( rele'nse for unrestricted use. To facilitate" verification by NRC, termination radiation survey plans should be developed in close coor~dination with the staff. 7
Z.L , . _ . . . _.-_ _ . - . . - _ . _ _ . .
, c .
( , 3.1.2 Proceses Plan In this section the licensee shou 1c cascribe the plan to demonstratt tnat the facility and site meet criteria for release for unrestricted use. Description i should in'clude such things as (1) the proposed method ,for assuring that sufficient ; data and all pertinent structures, systems, components, and site are included in the . survey (diagrars and plant layout drawings may be used to facilttate presenta-tion), (2) the type and magnitude of radiation readings, (3) the type and operating , ctndition of instruments used, (4) procedures used to obtain and analyze data,
~
and (5) procedures used for auditing and ' verification ,cf cata. A final radiation survey should be planned and designed so that procedures, results, and inter-pretations can be easily analyzed and verified. .
. 3.2 Evaluation of Termination Ractation Survey
( In this section the licensee should present 'an acceptable sampling plan, i.e'., demonstrate that radiation survey results wil,,1 have a high degree of assurance of characterizing the radiation conditions of the facility and site. O D x . x 9 O k e ( k
- e v *- ww-w---.-w-,.--,me._.- __
_m _ _ _ _ . _ _ . . _ . . . . _ _ _ . _ _ _ . . a g INiitTE) STATES I NUCLEAR RE2ULATORY CCMM:3SION ' t {. nEneN V 14s0 MARIA LANE,sulTE 210 WALNUT CREEK, CALIFORNIA s4Sas DEC 011983
.3 Docket No.'50-133 ,.'
,o .
us- . Pacific Gas and Electric Company 77 Beale Street, Room 1435 . San Francisco, California 94106 Attention: Mr. J. O. Schuyler, Vice President Nuclear Power Generation, Licensing Gentlemen:
Subject:
NRC Inspection , Humboldt Bay Unit 3 This refers to the special inspection conducted by Mr. G. Hamada of this office on November 7-10, 1983, of activities authorized by NRC License No. DPR-7, and to the discussion of our findings held by Mr. Hamada with Mr. R. T. Nelson and other members of your staff at the conclusion of the inspection. , Areas examined during this inspection are described in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with i personnel, and observations by the inspector. No items of noncompliance with NRC requirements were identified within the scope of this inspection. In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room unless you notify this office. by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the requirements of 2.790(b)(1). ' I e e e
\
w l
r Pacific Gas and Electric Company - DEC 011983 ( , z Should you have any questions concerning this inspection, we will be glad to discuss them with you. ,
~
Sincerely, f8l
'~'.. , ..t .
F. A. Wenslawski, Chief
~ .
Radiological Safety Branch
Enclosure:
Inspection Report No. 50-133/83-03 cc: P. A. Crane, Attorney, PG&E J. D. Shiffer, PG&E S. D. Skidmore, PG&E < E. Weeks, Plant Superintendent, PG&E (Humboldt Bay) - ir , bec: RSB/ Document Control Desk (RIDS)
; Distributed by RV: ,
JBN State of California Project Inspector t i RYsf[da:dh [ G.Hama F.Wenslawski 11/30 /83 11/g /83 (
~ - - - - , , , . . . . . . - , , -. -
-o
\
U. S. NUCLEAR REGULATORY COMMISSION REGION V Report No.- 50-133/83-03 Docket No. 50-133 License No. DPR-7 - Licensee: Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106 Facility Name: Humboldt Bay Unit 3 Inspection at: Eureka, California Inspection conducted: November 7-10, 1983 Inspector: - 42A244 // /.F4!83 G. Hamada, Radiation Laboratory Specialist Date Signed Approved By: . h!J /J F. Wenslawski, Chief, Radiological Safety Branch Date Signed ( Summary: Inspection of November 7-10, 1983 (Report No. 50-133/83-03) Areas Inspected: This was an unannounced special inspection of activities j associated with decommissioning of Unit 3. This inspection involved 20 hours i onsite by one inspector. Results: No items of noncompliance were identified in the areas inspected. l e
- k go-O'}-2 7-- bg
\
s DETAIL '
- 1. Persons contacted
*R. T.. Nelson, Power Plant Engineer
*R. C. Parker, Senior Rad-Protection and Chemical Engineer .
*D. A. Peterson, Quality Control Supervisor . .
- Indicates those present at exit interview.
- 2. Introduction -
This inspection was conducted to determine the status of decommissioning activities currentiv underway for the nuclear generating unit (Unit 3). While a formal decommissioning plan will not be ready for submittal to the NRC for review until March or April of next year, those activities that are permitted under existing regulatory constraints, such as shipments of waste to burial facilities, are currently in progress. Plans for the near term as well as for the longer term were also discussed with the licensee. The licensee has designated Mr. R. T. Nelson as the decommissioning project manager for the facility.
- 3. Discussion The licensee's broad plan is to maintain Unit 3 under a " safe-store" '
condition for the next 30 years or so. In general, this means removing and disposing of as much of the radioactivity contained in the plant as is feasible, controlling access to the remaining higher radiation areas,
, and maintaining a minimal surveillance program for areas that require periodic access or are required to remain operational.
A full component of fuel is still contained in the reactor. One fourth of this is fresh unirradiated fuel. If the fresh fuel can be adequately cleaned, the licensee plans to store it in the fresh fuel storage area. The spent fuel,will be transferred to the spent fuel pool and maintained in this location until a decision is forthcoming on what to do with spent fuel. Liquid Waste Reactor Vessel - Approximately 60,000-70,000 gallons of reactor water remain'in the reactor vessel. This water needs to be treated (demineralized) for disposal in the effluent canal. -The reactor vessel may be refilled with clean water for shielding purposes. Condenser Hot Well - Approximately 10,000 gallons of water need to be
- cleaned up before disposal.
Suppression Chamber - Approximately 180,000 gallons of contaminated water containing chromates need to be treated for both radioactivity and s chromates prior to disposal. NOTE: Activities involving the above three items are expected to commence sometime early next year. i,( .
o
' 2 '
1 Spent Fuel Pool - After the various categories of contaminated materials currently residing in the spent fuel pool have been characterized and ( shipped to a burial facility and the pool cleaned (vacuumed to remove sediments), spent fuel pool water integrity will be maintained with new demineralizers or through use of the existing condensate demineralizers. Some kind of emergency fill line will be provided and a system to monitor pool and liner water levels will be maintained. - Closed Cooling Water System - Approximately 20,000 gallons of
- contaminated chromated water are estimated to be present in this system.
This water requires processing ' prior to disposal. Rad-Waste Tanks - Approximately 8,000 gallons of liquid waste almost saturated with Na2 SO 4 , Na a cr0 4 , Na:C03 , etc. are on hand. It is likely that most if not all of this waste will be solidified. Condensate Demineralizer System - Approximately 500 gallons of liquid waste which require processing are contained in the system. Laundry Waste Tank - Approximately 200 gallons of liquid waste which require processing are contained in this system. Condensate Storage Tank - System has been flushed out and drained, and is currently dry. Pumps have been overhauled. Reactor Equipment Drain Tank - System has been cleaned (solids removed) and pump has been overhauled. This system is currently in operation.
, Turbine Building Drain Tank - System has been cleaned (solids removed).
This system is currently in operation and will continue to remain operational even after the plant has been placed in " safe-store" condition. During heavy rains, up to 800 gallons per day can be collected in this system. Caisson Sump - This system collects up to about 100 gallons per day of ground water (salt'H2O) through seepage. This system will stay operational. NOTE: Liquids from the Reactor Equipment Drain Tank, Turbine Building Drain Tank and Caisson Sump will be treated in the Rad-waste system prior to release. All four systems, therefore, will continue to remain functional. Reactor Cleanup System - Currently functional and operational, this syytes will be cleaned out and decommissioned after removal of fuel from the reactor. Control Rod Drive Hydraulic System - This system has been partially , drained. It will be fully drained when the fuel has been removed from l - the reactor. - s Reactor Shutdown Cooling System - This system is currently in nonoperational status. It will be fully decommissioned after removal of reactor fuel. 1(
( 3 - t Miscellaneous Liquids - Various smaller quantities of liquids in the plant will be removed and treated, as appropriate, prior to disposal.
.f Liquids remaining in various lines, liquids associated with resins in the A_ resin storage tank, etc., are in this category. During a walk through the various compartments of the plant, for example, a high survey meter reading was detected on a section of pipe associated with the air ejector system. The downward "U" bend in the pipe indicated that liquid was i
trapped in the "U" and that the activity was probably due t'o Sr-90 (Y-90). It is expected that all liquid traps will be drained and the plant brought to a " dry" status for " safe-store." NOTE: The volume of resin (plus water) in the resin storage tank is estimated to be up to 1,500 gallons. Since the tank has a capacity of 10,000 gallons, processing of this l system will be deferred until the latter stages of the decommissioning program, and thus permit this system to be used as needed. ! It should be noted that the liquid volumes indicated are in many cases only rough estimates and are not based on measured values. Solid Waste Rad-Waste Filters - Currently there are 48 drums of filters in the high level vaults. It is estimated that the high level vaults also contain l' about 10 drums worth of "unpackaged junk," i.e., bits and pieces el various contaminated materials. Feedwater Sparger - Currently resides in the spent fuel pool. Will need to be cut up for shipment to burial. Crud Bass - Two to three cubic feet of crud bags are currently stored in the spent fuel pool. An additional 2-3 cubic feet of miscellaneous springs, clips, etc. are also in the spent fuel pool. Stellite Balls and Pins - These are contained in buckets in the spent fuel pool. There are 368 balls (reall and large) and 368 pins (small and large) which were punched out from the control rod blades and followers. Several small pieces were measured and using conservttive assumptions, it was estimated that the total Co-60 activity was about 18,000 curies for the lot. (There appears to be some interest by certain commercial companies to use these Stellite pieces as Co-60 sources.) Feedwater Heaters - Two old feedwater heaters may be scrapped if they can be decontaminated. Otherwise they will be removed for burial. Sand Filters - Three boxes of sand filters G%#70 ft 3), which have been in nonoperational status since the mid-sixties, and which currently read
, 2-3 mr per hour are included in the solid waste inventory. .
Hot Spots - Hot spots in various in plant lines will be cut out for disposal. j!
i, ' 4 i , s . Gas Scrubber Column - Expectation is that this will be torn down and shipped to burial. is Asbestos Insulation - Much of this may be required to be disposed of as radioactive waste, but the stripping and packaging of this material will require special care. . Miscellaneous Scrap - Included in this category are, contaminated tools, other contaminated equipment, compactable waste, soil, etc. There is an
' area of ground in the exclusion area that was contaminated when the radwaste tank overflowed someey'ars ago. Some of this soil may need to
!, be removed for burial. Other lesser contaminated areas may be paved over as an interim measure. Also, when the radwaste tank overflowed, some of this overflow entered the storm drain line which discharges to the canal. This pipe may need to be removed for radwaste burial. Chemical Cleaning of Various Internals and Plumbing Systems - The possibility of using chemical cleaning on selected systems is being considered. A decision on what to do with the effluent canal has not been made as of this date. It was agreed, however, that the contents of the canal will need to be more fully characterized through sampling and analysis of sediments. Samples of groundwater as well as soils from selected areas i also will be analyzed. It is anticipated that the decommissioning (" safe-store") effort may take up to two years to complete. During this period, it is estimated that i approximately 100 truck loads of waste will be shipped to burial, an average of about one shipment per week. As mentioned earlier, a decommissioning plan will be developed by early i 1984. Included in this document will be requests for Technical Specification changes consistent with a " possession only" license. Certain changes in the environmental monitoring program will also be made. Current Tech-Spec requirements for environmental monitoring is limited to maintaining 30 monitoring stations to determine integrated gamma dose rate in the environs of the plant. Because of State of California requirements, however, a more extensive environmental monitoring program has been in place and currently, samples such as milk, particulate air filter, marine biota, etc. are still being assayed on a routine basis. It is expected that only the marine sample collection and analysis program will be maintained.
- 3. Exit Interview An exit interview was conducted with licensee personnel indicated in paragraph 1. Inspection findings were discussed to determine whether or not inspector perceptions were consistent with decommissioning plans and
. objectives. It was emphasized that while the broad decommissioning plan is as stated, schedules and procedures for specific operations are at best only rough estimates at this time. It was agreed that better estimates of radioactivity identity and quantity for various categories
(
5 ( ) of waste for shipment will be needed after December 27, 1983, when 10 CFR 20.311 becomes effective. ( O e i l r } . . 1 r '( . e w w- ,
t, t. , i C0' METE.- UN' UNITED STATES OF AMERICA (- , NUCLEAR REGULATORY COMMISSION P
'84 FEB -3 A10:15 ATOMIC SAFETY AND LICFNSING BOARD 07:;E cr st., :: .
Before Administrative Judges: 00C.'.Eij:gtF,. Robert M. Lazo, Chairman 8 Gustave A. Linenberger David R. Schink SERga FEB W4
)
In the Matter of ) Docket No. 50-133-OLA
)
PACIFIC GAS AND ELECTRIC COMPANY ) ASLBP No. 77-357-07 LA ' (Humboldt Bay Power Plant, l - Unit No. 3 - Amendment to Facility ) OperatingLicense) ) February 2,1984
)
MEMORANDUM AND ORDER I On January 26, 1984, Joint Intervenors filed two documents in this proceeding, one entitled " Opposition of Intervenors to PG&E's Request for Deletion of Item E(2)(e) of Their Operating License" and the other entitled " Statement of Intervenors With Respect to Public Involvement in Deconnissioning Plan." From an examination of the two documents, it appears that Joint Intervenors have made only one direct request to the Licensing Board, 1 Joint Intervenors are Thomas K. Collins, Dr. Elmont Honea,
~ Frederick P. Cranston, Wesley Chesbro, Demetrios L. Mitsanas, Six Rivers Branch of Friends of the Earth and the Sierra Club.
940GO60062-840202 n# -' PDR ADOCK 05000133 PDR C ,
- [ (6 a
~
^-
Q.Y ( name-If that PG&E's decommissioning plan be made available generally to the public and be furnished specifically to the Joint Intervenors as soon as PG&E submits it to the NRC.2 Additional matters raised by Joint Intervenors indirectly suggest that the Licensing Board may want to take some action regarding them. To assist the Licensing Board in its determinations regarding the disposition of the two pleadings filed by Joint Intervenors on January 26, 1984, it is requested that PG&E and the NRC Staff submit their consnents regarding these documents. Responses should be filed within 15 , days after service of this Memorandum and Order. . It is so ORDERED. , FOR THE ATOMIC SAFETY AND LICENSING BOARD Rrbd n).!aa a f Robert M. Lazo, Chairman ' b ADMINISTRATIVE JUDGE Dated at Bethesda, Maryland, this 2nd day of February,1984. 2 In a letter dated December 28, 1983, addressed to the Members of
- the Licensing Board, PG&E stated that it plans to submit a t deconunissioning plan to the NRC Staff by April 1984.
h Y {) s 1 9 PACIFIC OAS AND EI,E C T RI C COMPANY 96**i sb . y 1034 SIXTH STREET . EUREKA, C ALIFoR NI A 95501 . (707) 443 2787 E. D. WEEKS
,Last anAM*,Et peuCLEAR ,LANT OPERA %ons. esse,oLot
_ February 3, 1984 Office of Management Information and Program Control U. 5. Muclear Regulatory Commission Washington, D.C. 20555 Re: Docket No. 50-133 License No. DPR-7 Gentlemen: Enclosed are the completed monthly report forms and the narrative of operating and major maintenance experience for Humboldt Bay Power Plant Unit No. 3 (HBPP-Unit 3) for January, 1984. These forms and the narrative are submitted in accordance with Section IX I.1.c of our Technical Specifications. Sincerely, E. D. Weeks Plant Manager. Humboldt Bay Power Plant 1034 Sixth Street Eureka, California 95501 (707-443-2787) Enclosure j e cc: Mr. J. D. Shiifer g 2 _ Mr. B. S. Lew .$ O e .Q Mr. J. O. Schuyler ? J.?
_*I Mr. John B. Martin y
Regional Administrator
- U. S. Nuclear Regulatory Commission 3 i Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 EDWeeks:me 21 po3020coC Gy ,
,)
( ,. MONTHLY NARRATIVE REPORT D OF OPERATING AND MAJOR MAINTENANCE EXPERIENCE This report describes the operating and major maintenance experience for , the month of January 1984. This report was prepared by the Plant Staff and is submitted in accordance with Section IX:I.1.c. of the Technical - Specifications. During the, report period, final core unload was begun. On January 10
- the head was removed from the reactor, and the extension tank and service platform were placed on the vessel. On January 14 and 15, fuel movements were made in the spent fuel pool to accommodate the fuel to be received from the reactor. From January 24 to 26, new fuel was transferred from the reactor to the new fuel storage vault. On January 30, movement of spent fuel from the reactor to the spent fuel pool was begun. Fuel moves continued to the end of the reporting period, t
O
----.yr -w-e + ,ww - -r -m w , ---,m,
k. C OPERATING DATA REPORT DOCKET NO. /83 DATE _ 2-2-83 COMPLETED 11Y _g5EE41(S TELEPilONE 707/'/'/9-2767 OPERATING STATUS I. Unit Name: NUNCOLor EAv ?cWE,1 LMT-(bhr3 N"'"
- 2. Reporting Period: 7A Al#A 4.V /98 V
- 3. Licensed Thermal Power (MWr): 220
- 4. Nameplate Rating (Gross MWe): 6s
- 5. Design Electrical Rating (Net MWe): 46
- 6. Maximum Dependable Capacity (Gross MWe): 65
- 7. Maximum Dependable Capacity (Net MWe): 68 .
- 8. If Changes Occur in Capacity Ratings (Items Number 3 Through 7)Since Last Report.Give Reasons:
///A
- 9. Power LevelTo Which Restricted.If Anv (Net MWe): M!/i
- 10. Reasons For Restrictions. If Any: M/A i
This Month Yr. to Date Cumulatise
- 11. Hours In Reporting Period 7YV 7YV /79786
- 12. Number Of flours Reactor Was Critical O o 9 6'l71
- 13. Reactor Resene Shutdown flours 0 0 O
- 14. Hours Generator On Line 0 0 97252.
- 15. Unit Resene Shutdown Hours O o O
- 16. Gross Thermal Energy Generated (MWH) O M /C 6/ 8, 456
'l7. Gross Electrical Energy Generated (MWil) o_ _ __.
o V,7 79. 732
- 18. Net Electrical Energy Generated (MWH) f> d $ 5J6,354
- 19. Unit Senice Factor O M SV. / %
- 20. Unit Availsbility Tactor O o JM1 %
l l 21. Unit Capacity Factor (Using MDC Net) o O Va.1 % ! 22. Unit Capacity Factor (Using DER Net) O O 38.8 %
- 23. Unit Forced Outage Rate o d /. 9/ #/o l 24. Shutdowns Scheduled Over Next 6 Months (Type.Date.and Duration of Each):
y/A l
- 25. If Shut Down At End Of Report Period.Estima:cd Date of Startup: N C D ^'^1' 5 f lo d /^/6
- 26. Units in Test Status (Prior to Commercial Operatiun): Forecast Achiesed r .
! INITIA L CRITICALITY INITIA L ELECTRICITY COMMERCIAL OPERATION L (9/771
- f. .
. - - _ _ - . _ _ - - - - . _ _ --. - .~.
i-:;i
.IlII Il.l'1 IljtIil l1 Ili1!i ,l'Il g
QH 7g. IN4 M C2*i. M%C8ot2" >*O mo*m3 MmCCngo7ta c3H2>rm tG gg IL U 3 g Cyqm Ni*8 noC f gg, QmC a<- %wt9ARn y ym3nAgozd 9bzC5g% HmFQ Ozm q2vNt%WiNa% 4 3r t f o n e5 n) os i-n ogt n c rgaga m4 n nacE > Oc" 2r.g I o di a eC o dc
>nr ir -
- z. 0N N t a u o
s a ot e h uR t rnE ts d yU P o :
/ r e
mc% SC mC pa<E Nne.E;;an* T D( uH R t eh n M S wo a C o - D
&egD
~
M 4KC.- Ok - As 1O %toS D gob %h%phDDgg QDOao s 7
- a w b "
- . mkE O*5n,* 3.
- m. mO5nc.
. Wou*O".. ' : -
Iau0o . p' ma3u-
" ca c C" u M. mCbCcXc-
>.mo.c. 53aE mug,a nmx3 S ru3cu. m dx M o2" c, rE' 2aS Yru3=u m2u3' u.Iu "-@aR" o' 40- m,E Mnmc2 rmB ~s* ~ycwmO Y>c~9=".W mQSu-G.ma9E.5, . .
. ^ o="2 m5 UO o.S-C.waeE" cQ won =2.Cs r
t t gMma .a= 08 a .nUI, t e33n > I m.O
- - *a m.>c=E5 E,tn; ; mxEE .mS=o a nRo O.ca nC c.5, . =: mu s~ o- .
"9.4Qv =.O " 0 . {u=O
AVERAGE DAILY UNIT POWElt LF"T.L ( i b DOCKET NO. 60-/83 UNIT H BPP M3 DATE 2*2"8'/ COMPLETED BY ASEffk5 TELEPilONE 707,!'NS-27/7 MONThi 7 ANN DAY AVERAGE DAILY POWER LEVEL DAY AVERAGE DAILY POWER LEVEL (MWe Net) (MWe-Net) I O 17 2 18 3 19 4 20 5 21 6 22 7 23 8 24 9 25 10 26 11 27 12 28 13 29 i l 14 30 31 '/
. 15 l 16 V ,
INSTRUCTIONS On this format.hst the average daily unit power level in MWe Net for each day in the reporting inonth. Compute to
,t,he nearest whole megawatt.
t (9/771 4
l (i _ b .
. PACIFIC OAS AND E LE C TRIC C OMPANY . (415) 701 4211 l- .
. S AN FR ANCISCO, CALIFORNI A 94106
- LAW DEPARTMENT - 77 s E A.LE STREET, 31ST F LOOR October 1, 1982 Judge Robert M. Lazo, Esq. , Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555 Judge David R. Schink Atomic Safety and Licensing Board Department of Oceanography Texas A&M University College Station, TX 77840 Judge Gustave A. Linenberger Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission
. Washington, DC 20555 Re: Deckat No. 50-133, OL-DPR-7 Humboldt Bay Power Plant, Unit No. 3 Third Quarterly Status Report Gentlemen:
i In its Memorandum and Order (" Order") dated February 16, 1982, l ! .the Board directed PGandE to file a detailed status report with the Board
' starting April 1, 1982, and each three months thereafter, until final l resolution of the future operation of Humboldt Bay Power Plant, Unit No. 3.
Raclosed is Pacific Gas and Electric Company's third quarterly status report, dated October 1,1982. This report summarizes the current
- plant status and status of PGandE's activities.
I 1 f I e _.FAlk /
-3.eguo -
ff o, 4 (). - 13 1 - - - - - . - - _ - ___ _ _ _ _ _ -s,-mg.,. _ , _ _
et
)
( Octobsr 1, 1982 Judge Robert M. Lazo, et al. In accordance with Item 1 of the Order, PGandE will complete otudies to support a der.ision regarding the future disposition of the Humboldt Bay Power Plant, Unit No. 3, within six months of the issuance l 'by the_ NRC of a final reactor safety policy statement and its associated goa s cnd guidelines. Respectfully submitted, b ROBERT OHLBACH PHILIP A. CRANE, JR. RICHARD F. LOCKE Attorneys for Pacific Gas and Electric Company By: /s/ Richard F. Locke Richard F. Locke cc: Service List Enclosure bec: (w/ enc.) Mr. R. H. Engelken Regional Administrator Mr. Vern Rooney Project Manager Mr. Dominic Vassallo Chief Operating Reactor Branch No. 2
I (>
' PACIFIC GAS AND ELECTRIC COMPANY HUMBOLDT BAY POWER PLANT, UNIT NO. 3
=
Ouarterly Status Report October 1,1982 . n Since'PGandE's last status report dated July 1,1982, activities on Hunboldt Bay Unit 3 can be broken down into five categories as discussed below: l
- 1. Plant Operational Status Humboldt Bay Unit 3 continues to be maintained in a cold shutdown condition. TheThe reactor coolant system is filled with reactor coolant but reactor vessel head and shield plug are in place.
depressurized. ' The reactor vessel head and shield plug are in place. The reactor core is loaded with 184 fuel assemblies 44 of which are new fuel assemblies. In the spent fuel pool, 250 spent fuel assemblies continue to be stored. There are 236 empty spaces remaining in the spent fuel pool. The control rod drive system is Reactor control rods are fully inserted. de-energized and cannot be re-energized without the knowledge and consent In addition, the control rod hydraulic system is
- of the shift foreman.
This system would need to be filled and vented before i depressurized. The emergency boration system, reactor control rods could be withdrawn. clean up system, liquid radwaste processing system, refueling building ventilation system, nuclear instrumentation, and radiation monitoring ' systems are all maintained operational. Surveillance testing is performed as required by the Technical Specifications. Fire protection, radiation protection, material accountability, radioactive waste management, training and quality ' assurance programs are being implemented and are audited by NRC's Region-l V inspectors. PGandE has continued to comply with the shift manning requirements for the shutdown mode in accordance with the Humboldt Bay Technic Specifications. available to cover four shifts are the following: l > a. 5 Senior Operator Licensees, SQL (4 Shift Foremen,1 Relief Shift l Supervisor).
- b. 10 Operator Licensees. OL (S Control Operators, 5 Senior Control Operators).
I c. 5 Management personnel at the plant who hold a current SOL to supplement the operating staff if needed. g5.O l N J3F 1
(- l s PGandE has continued to fully comply with the16,latest dated November 1976. (Revision This 2) Humboldt Bay Power Plant Security Plan Any security plan has been approved by the NRC Staff as being adequate. , further changes in the Plant Security Plan will be submitted to the NRC , Staff in accordance with current regulations. Reports regarding Unit 3 are routinely submitted These include: to the NRC as requi' Monthly Operating by the license cr.d other regulations. Status Reports; Radioactive Effl , and Licensee Event Reports, if required. Scheduled and unscheduled inspections of the plant have been conducte Any violations the NRC's Inspection and Enforcement Region V Inspectors Staff. No revisions or modifications in the Humboldt Bay Unit 3 design or operation have been made that would bear upon th no risk to the health and safety of the public. .
- 2. Plant Improvements PGandE has completed construction of a new low level radwaste storageThe n building on the Humboldt Bay Power Plant site. The a weather protected radioactive waste storage and handling area. Storage building was designed to meet all applicable NRC requirements.
in the new building commenced in September,1982. 2
- 3. Monitoring of the NRC's Safety Goal Rulemaking
_As noted in the Order, the NRC has published for Acoment report a proposed policy statement on safety goals for nuclear power plants. discussing the development of the proposed policy statement has been published separately as NUREG-0880, Safety Goals for Nuclear Po A Discussion Paper. Plants: final policy recommendations early next year.
- 4. Review of New NRC Requirements for Operating Nuclear Plant PGandE is continuing to review NRC promulgated information such as Circulars, Bulletins. Information Notices, NUREGs, PGandE's review also i
Bay plant in its current cold shutdown status. considers the potential for significant safety problems associated with the plant for all other operational modes and considersThose those actions which are necessary to comply with the intent of HRC requirements. applicable requirements which are not imediately acted upon are on a list of work items that must be satisfactorily resolved prior to
% start to Unit 3.
l \ NR.__9 - - - - - -
., I
()
, b
- 5. Evaluation of Steam Plant Ccnversion Alternatives PGandE is progressing in its evaluation of various h fossil fired ste ,,
system conversion alternatives. decommissioning of the nuclear portion of dUnit 3 while use with a retaining t power generation portion of the plant available for continue . new steam supply source. a coal
)
The alternative steam supply systems The evaluations, bility and being evalu " fired boiler; and a combined cycle waste heat boiler. parts of which are now complete, focus on engineering l feasi ), trade-offs, fuel supply and transportation, pollution contro t t requirements, cycle efficiencies, waste manage , and operation and maintenance costs, i i N l I
. 6 t
! . - ~ . .
.11F 3 ' -- -- - - - - _ _ - _ ___ '-"O w. , _,_
I ( b . UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
=
)
)
In the Matter of ) Docket No. 50-133
) License No. DPR-7
- PACIFIC GAS AND ELECTRIC COMPANY
)
(H"=holdt Bay Power Plant, Unit No. 3) _ _ _) m CERTIFICATE OF SERVICE d Electric The foregoing document of Pacific l Gas ani g by deposit in the Company has been served today ondthe addressed: fol ow n United States mail, properly stamped an Robert M. Lazo, Esq., Chairman Atomic Safety and Licensing Linda J. Brown, Esq. Board Panel 100 Van Ness Avenue, 19th Floor U.S. Nuclear Regulatory Commission l i San Francisco, CA 94102 Washington, D.C. 20555 Mitzi Young, Esq. Mr. Gustave A. Linenberger, Member Office of Executive Legal Atomic Safety and Licensing Director Board Panel BETH 042 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission 20555 Washington, D.C. Dr. David R. Schink Department of Oceanography Secretary Texas A & M University 77840 U.S. Nuclear Regulatory College Station, TX Constission 20555 j washington, D.C. Docketing and Service Michael R. Sherwood, Esq. Sierra C Attn: l Section 2044 Fillmore Street94115 San Francisco, CA Gretchen Dumas, Esq. California Public Utilities Commission 350 McAllister, Room 5243 San Francisco, CA 94102 Dated: October 1, 1982 A # t
~
RICHAND P.' LOCKE Attorney Pacific Gas and Electric Company
, .a
/ %, UNITED STATES
; E'- g NUCLEAR REGULATORY COMMtSSION Ofgbf*'E0 fj,'
g .j WASHINGTON. D. C. 20555 k . .s.. * ./ November 3,1982 //!! Ai07 /g I:59
. 6ECle;,,,,. ,
Docket No. 50-133 Mr. P A. Crane Vice President and General Counsel Pacific Gas and Electric Company 77 Beale Street, 31st Floor San Francisco, California 94106
Dear Mr. Crane:
The Commission has issued the enclosed Exmption from the requirments of 10 CFR 50.54(w) relating to obtaining property damage insurance for the Hubmoldt Bay Power Plant, Unit No. 3, in response to your request dated May 28,1982. A copy of the Notice of Granting an Exmption is also enclosed. Sincerely, Domenic B. Vassallo, Chief Operating Reactors Branch #2 Division of Licensing
Enclosures:
- 1. Ex mption
- 2. Notice
, cc w/encls: l_ See next page i i G O
. r l
h~Y
Mr.. Philip A. Crane, Jr. Pacific Gas & Electric Company cc: . Mr. James Hanchett ' Public Information Officer Michael R. Sherwood, Esq. Region V - IE Sierra Club Legal Defense U. S. Nuclear Regulatory Commission Fund, Inc. 1990 N. California Boulevard 2044 Fillmore Street Walnut Creek, California 94596 San Francisco, California 94115 Mr. Eric W. Hedlund . Linda J. Brown, Esquire Humboldt County Board of Supervisors Donohew, Jones, Brown & Clifford County Courthouse 100 Van Ness Avenue,19th Floor 825 Fifth Street San Francisco, California 94102 Eureka, California 95501 Dr. Perry Aminoto Bruce Norton, Esq. Department of Conservation 3216 N. Third Street, Suite 202 Division of Mines & Geology Phoenix, Arizona 85012 1416 9th Street, Room 1341 Sacramento, California 95814 - Friends of the Earth .
. ATTN:. Andrew Baldwin 124 Spear Street San Francisco, California 94105 California Department of Health ATTN: Chief Environmental Radiation Control Unit
- Radiological Health Section 714 P Street, Room 498 .
Sacramento, California 95814 . U.S. Environmental Protection - Agency Region IX Office Regional Radiation Representative 215 Freement Street l San Francisco, California 94101 / =v Robert H. Engelken Regional Administrator, Region V - ! U.S. Nuclear Regulatory Commission - 1990 N. California Blvd., Suite 202 WalnLt Creek, CA 94596 ) %=m
. =
- i
. '. , 7590 01 NUCLEAR REGULATORY COMMISSION In the Matter of )
)
Pacific Gas and Electric ) Docket No. 50-133 - Company ) (Humboldt Bay Power Plant, ) Unit No. 3) ) EXEMPTION I. The Pacific Gas and Electric Company (the licensee) is the holder of Facility. Operating License No. OPR-7 which authorizes ooeration of the Humboldt Bay Power Plant, Unit No. 3 (Humboldt). This license provides, among other things, that it is subject to all rules, regulations and orders of the Commission now or hereafter in effect. The Facility is a boiling wat'er reactor rated at 63 Hw(e) at t'h'e licensee's site located near Eureka, California. II. The regulation,10 CFR 50.54(w), requires that each comercial power reactor licensee shall, by June 29, 1982, take reasonable steps to obtain on-site property damage insurance available ati reasonable costs and 'on reasonable terms from private sources or to demonstrate to the
- satisfaction of the Comission that it possesses an equivalent amount of' protection covering the facility, provided, among other things, that "this insurance must have a minimum coverage limit no less than the
( combined total of (i) that offered by either American Nuclear Insurers Y
=r" r - - - - v+rwc- - e w e r.,w- e-w -w- -
----w - - -
c 90 01 (ANI) and Mutual Atomic Energy Reinsurance Pool (MAERP) jointly or Nuclear Mutual Limited (NML); plus (ii) that offered by Nuclear Electric Insurance Limited (NEIL), the Edison Electric Institute (EEI), ANI and MAERP jointly, or NML as excess property insurance." On May 28,1982, the licensee filed a Request for Exemption from 10 CFR50.54(w). In suoport of this request, the licensee indicated that Humboldt Unit 3 has been shut down since July 1976 and is presently in cold shutdown condition. The licensee indicated that studies conducted by it and the NRC staff conclude that the unit presents no danger to the health and safety of the public. Further, the licensee presently maintains all-risk property damage insurance at Humboldt Unit 3 in the amount of approximately $100,000,000 which, in the licensee's opinion, .
~ ^
is more than enough to cover the very remote possibility of any damaqe to the unit. The licensee submitted that any additional insurance beyond that currently carried should not be required. In addition, the licensee st3ted that the annual premium for additional insurance would be a burden on its ratepayers. The licensee did not provide sufficient information in its exemption request for the Connission to conclude that a permanent exemotion to the
- requirements of 10 CFR 50.54(w) is justified. Consequently, the Commission requested additional infonnation from the licensee in a letter dated June 24, 1982. The licensee has responded to this request by letter
~
dated July 28, 1982. l l
; \ ,
7590.cs Because of the additional infonnation provided by the licensee in its July 28th letter and by staff studies perfomed for the Humboldt~ unit, the Commission is able to consider the exemption request on its merits. The Commission finds that the risk to public health and safety presented by the Humboldt unit in its present state cf cold shutdown is very low compared to operating reactors. In a recent decision, the Director, Office of Nuclear Reactor Regulation declined to order decomissioning of the Humboldt unit as requested by an individual pursuant to 10 CFR 2.206. (DD-82-7; July 7,1982) The Director found, in part: "The consequences and types of accidents are greatly diminished because of the oresent condition of the plant. Staff analysis has concluded that Humboldt Bay fuel has decayed sufficiently that air cooling is adequate to preserve fuel cladding integrity. Therefore, measures to assure-core cooling or mitigate loss of coolant consequences are unnecessary. Due to the long period since the reactor last operated, mobile radioact'vity has decayed very significantly." To illustrate, decay heat in the core of a reactor similar in configuration and cold shutdown status to the Humboldt unit is estimated by staff to be approximately 3.0 X 10-5% of full power.
. Additionally, preliminary infomation has been developed for the Commission's accident cost study of light water reactors (Technology, Safety and Costs of Decommissioning at Reference Light Water Reactors Involved in Postulated Accidents; Pacific Northwest Laboratory: NUREG/CR-2601; to be oublished). This report considers three accident scenarios all of which involve loss of coolant accidents of varying severity.
Such accidents are considered to present the greatest potential .for ._,
i i {}jg041 l excessive contamination requiring significant cleanup expense. As indicated above, the staff does not consider loss of coolant accidents
- to be credible events for Humboldt in its current status. Consequently, it .is reasonable to expect that whatever on-site decontamination costs that might arise from an accident at the Humboldt unit in its current state would be covered by the $100,000,000 all-risk property damage insurance currently maintained by PG&E.
Finally, the additional property insurance required to comply with - 10 CFR 50.54(w) would require an additional annual premium of from J
$610,000 to $691,000. The Commission finds that this financial burden, if placed on the licensee and its customers, would not be warranted by the marginal additional benefit that would be obtained. .. .
Accordingly, based upon the additional information provided by the licensee in its July 28 letter, the Commission has determined that . pursuant to 10 CFR 50.12 an exemotion is authorized by law and will not endanger life or property or the common defense and security and is ! otherwise in the publit interest. Therefore, the Commission hereby approves the following exemption: The licensee is exempt until further notice fron the requirements of 10 CFR 50.54(w), with respect to on-site property damage insurance, in excess of $100,000,000 unless and until such A time as Humboldt Bay Power Plant, Unit No. 3 is removed from cold shutdown and resumes operation.
( . 1 7590 01 The NRC staff has determined that the granting of this exemption will not' result in any significant environmental impact and that pursuant to 10 CFR 51.5(d)(4) an environmental impact statement or negative declaration and environmental impact appraisal need not be prepared in connection with this action. This exemption is effective upon issuance. FOR THE NUCLEAR REGULATORY COMMISSION Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation Dated at Bethesda, Maryland this 3rd day of November 1982. M s* I e l l - l l I
- e l
7590-01 UNITED S M ES NUCLEAR REGULATORY C00 MISSION
~
DOCKET 100. 50-133 PACIFIC GAS AND ELECTRIC COMPANY
; NOTICE OF GRANTING AN EXEMPTION FROM THE REQUIREMENTS OF 10 CFR 50.54(w) i J
The U.S. Nuclear Regulatory Commission (the Commission) has granted ~ari exmption from the requirements of 10 CFR 50.54(w) to the Pacific Gas and ! Electric Company (the licensee). This exemption related to a requirement for obtair.ing property damage insurance for the Humboldt Bay Power Plant, Unit No. 3~. The basis for this action is set forth in the Commission's Exemption dated November 3 , 1982. The Commission has determined that the granting of this exemption will not result in any significant enviromental impact and that pursuant to 10 CFR Section 51.5(d)(4) an enviromental impact statement or negative declaration and environmental impact appraisal need not be prepared in . connection with this action. . For further details with respect 'to this a'ction, see (1) th'e liceniees request dated May 28, 1982; (2) the Commission's tenporary exemption dated June 29,1982; and (3) the Commission's Exemption dated . November 3,1982. l - Items (1), (2) and (3) are available for public inspection at the Commission's ' Public Document Room,1717 H Street, N.W., Washington, D.C. and at the Humboldt County Library, 635 F Street, Eureka, California 95501. A copy of iten (3) may be obtained upon request addressed to the U.S. Nuclear Regulatory Commission Washington, D.C. 20555, Attention: Assistant Director, State and Licensee Relations, Office of State Programs. l Dated at Bethesda, Maryland, this 3rd day of November 1982. FOR THE NUCLEAR REGULATORY COMMISSION
~
t Domenic B. Vassallo, Chief
; (f Operating Reactors Branch #2 Division of Licensing
-r l
U .] C ?" PACIFIC OAS AND E LE C T RIC C O M PANY ~ pgg , ,yr statt svaret, saw rnancisco catironnia ,4 os retteno=r <4 s> tat 42it
.c July 15, 1983
# 5 Mr. Ihrrell G. Eisenlut, Director Division of Licensing .
Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Cnemission Washington, D.C. 20555 Re: Docket No. 50-133, OL-DIR-7
.- Hunboldt Bay Ibwer Plant Unit No. 3 nac - iasioning Decision
- 3.
Dear Mr. Eisenhut:
7 Pacific Gas and Electric Coupany has recently dacidad to h - - -mi asion - Emboldt Bay Pbwer Plant Unit 3. ~The unit has been shut down since 1976, and an updated acwie analysis indicates that it would not be +:+-- ic=11y feasible to restart the unit. PGandE intends to unload the R aboldt reactor core and store the spent fuel in the spent fuel pool at the site until the Department of Energy has a repository in operation. Ebrther, PGandE will request that the Haboldt Bay Unit 3 Operating Licanaa be amended to hac- a possession-only license in accordance with Regulatory mida 1.86, Termination of Operating Licenses". PGandE plans to. place the facility in custodial SAFSIER until final dace =+=ination is performed. IGandE would like to meet with Staff personnel h 4 pt 1983 to discuss l darn-insioning plans for the facility. We would <cy ej _1 your informing us of an acceptable date. Sincerely, J. O. Schuyler r
~
l ' cc: iJ. B. Martin, IRC Sewice List r . 3 22 4u 7 i7 OW, P f un
(pa l F.ECE!ygy;
!*.S PACIFIC GAS AND ELECTRXQQOgP,ANY t '
96V6 l 77 BEALE STREET . s.s.N FRANCISCO. CALIFORNIA 94106 . (415)781 4211 . Twx 910 372-6587 GIGiC t vy y J.O.SCHUYLER ses r.t:-et.T
.......u.....
July 26, 1983 Mr. John B. Martin, Regional Administrator U. S. Nuclear Regulatory Comission, Region V ~ 1450 Maria Iane, Suite 210 Walnut Creek, CA 94596-5368 Re: Docket No. 50-133 License No. DPR-7 Humboldt Bay Power Plant Unit No. 3 cmpliance with 40 CFR 190
Dear Mr. Martin:
( ' In January 1982, during a routine inspection by Mr. G. Yuhas of Region V, it was requested that an analysis be performed to demonstrate Humboldt Bay Power Plant, Unit No. 3 cacpliance with the limits of 40 CFR Part 190. The analysis has been performed and a smmry is attached.
'Ihe results of the analysis conclude that Unit No. 3 is in compliance with 40 CFR Part 190. A copy of the emplete report, including a listing of assunptions in the computer code, input parameters and resulting calculated doses, is available for inspection at Humboldt Bay Power Plant.
Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope. Sincerely, l Attactnent L n jg.WSD+N Y (' f $$*
SUMMARY
OF THE w ANALYSIS OF COMPLIANCE WITH 40CFR PART 190 _FOR THE HUMBOLDT BAY POWER PLANT ( INTRODUCTION Recent changes in Nuclear Regulatory Commission (NRC) regulations require that licensees engaged in uranium fuel cycle operations comply with the Environmental Protection Agency's Regulation 40CFR Part 190. This environmental protection standard requires that operations be conducted in such a manner as to provide reasonable assurance that (1) radiation doses to real individuals in the general public do not exceed annual totals of 25 millirems to the whole body, 75 millirems to the thyroid, and 25 millirems to any other organ; and (2) the total quantity of radioactive materials entering the environment from the entire uranium fuel cycle does not exceed 50,000 curies of krypton-85, 5 millicuries of iodine-129, and 0.5 millicuries combined of plutonium-239 and other alpha-emitting transuranic radionuclides with half-lives greater than one year, per gigawatt year of electrical energy produced by the fuel cycle. This report contains 'a summary of an analysis of the operation of Humboldt Bay Power Plant's_ nuclear unit to determine its current and future compliance with 40CFR Part 190. METHODOLOGY . The quantity limits established in 40CFR Part 190 for radionuclides ( entering the general environment apply only to those generated by the fission process af ter December 1,1979 for the alpha-emitting transuranics, and after January 1,1983 for krypton-85 and iodine-129. Since the nuclear unit at Humboldt Bay Power Plant has not operated since 1976, these limits do not apply an'd were not considered in this analysis. To determine compliance with the 40CFR Part 190 dose limits for members of the general public, it is necessary to consider doses resulting from radioactive effluents and doses resulting from direct and scattered radiation. Doses from direct and scattered radiation were determined based on site boundary radiation survey data and occupancy factors. Doses from radioactive effluents were determined based on offsite dose calculations using appropriate models. i. Doses From Liquid Efficents Doses to members of the general public from radioactive liquid effluents were calculated using the TECHSPEC computer code. The TECHSPEC code was developed by Pacific Cas and Electric Company and is based on the guidance contained in NUREC-0133. Results from TECHSPEC have been checked by , g hand calculations, and have been compared to corresponding results from the NRC PARTS code to assure calculations are performed in conformance with availabic guidance. In accordance with the NUREG-0133 methodology, (. offsite doses from liquid effluents from saltwater sites come from consumption of fish and invertebrates. l _ . ~ _ . _ ._ _
4
, Fcr currant plcnt conditions, tha input parameters for TECHSPEC (i.e.
total annual quantity of radionuclides released in liquid effluents,
. total quantity of effluent released and total volume of dilution water discharged) were taken from the 1981 Semiannual Effluent Release Reports.
k'. A continuous discharge was assumed during the year. To demonstrate future compliance, a second set of input parameters were prepared for the TECHSPEC code. For these parameters, it wa,s assumed that effluent and dilution volumes stayed at 1981 levels and annual release quantities of radionuclides were approximately one to two orders of magnitude above the 1981 totals. ~ If future releases of radionuclides remain below the values utilized in this case, it can be reasonably assured that resultant doses will remain below those calculated. This calculation is intended to provide an upper limit on possible doses to the general public from liquid releases. This upper limit value may be used in future analyses of offsite doses, if none of the annual release quantities of the various radionuclides used in the calculation are exceeded. It should be noted that a number of conservative assumptions were made in the calculations of doses from liquid effluents and actual doses should be substantially lower than the values derived. For example, no credit was taken for the dilution of effluent in the receiving waters - and uany of the radionuclides assumed to be in the effluent have not actually been detected. Quantity values for these undetected radionuclides were based on the maximum quantity that might be present, yet would remain undetected (i.e., the lower limit of detection for the instrument used in the analysis). Doses From Gaseous Effluents Doses to members of the general public from airborne radioactive releases were also calculated utilizing the TECHSPEC code. 4 - For current plant conditions, source terms (annual quantities of radionuclides released) were taken from the 1981 Semiannual Effluent Release Reports. For the assumed upper limit calculation, source terms were taken to be approximately an order of magnitude above the 1981 values. Meteorological input parameters (X/Q's and D/Q's) were taken from the report, " Analysis of Compliance with 10CFR50, Appendix 1 for the Humboldt Bay Unit 3 Nuclear Plant," that was submitted to the NRC in November 1976. The meteorological data used in the referenced report came from onsite measurements conducted during 1966 and 1967. Air doses were calculated at 51 locations for both the current and the upper limit cases. These locations included the critical distances in each of the sixteen compass sectors that gave the highest beta and gamma sir doses, as shown in the Appendix 1 submittal. l- g Organ doses, and annual dose rates from noble gases, were calculated at ' 21 locations for both the current and the upper limit cases. These locations included the critical distance in each compass sector, based ( on the location of the nearest dose pathway (milk cow, meat animal, vegetable garden, residence) as shown in the Appendix 1 submittal.
. , . - - - - - - - , ~ ---------a n-- - ----nn- ,,---w-- .--,n, .,
Dosas Frca Dirzet And Scattered Rrdintien s To determine doses to members of the general public from direct and [ scattered radiation for current plant conditions,ia site boundary ra-
\-
diation survey was conducted on August 18 and 19, 1982. This' survey , i involved taking measurements with calibrated pressurized ion chambers (Reuter-Stokes Model RSS-111, S/N 3579 and S/N 3580) at 16 locationsA around the site boundary, one measurement in each compass sector. . background measurement was made at a location approximately 10 miles from the plant in a predominantly upuind location. l 8 Measurements were taken and averaged over a minimum of 10 minutes at each location. Figure 1 shows the location where measurements were taken around the site boundary. The background control measurement was taken approximately one mile south of the Arcata airport. Table 1, taken from PGandE Department of Engineering Research Test 4 Report 420-82.283, provides the measured exposure rates and calculated exposure rates in excess of background at each location. To determine complia'nce on an ongoing basis, environmental thermolumi-l
, nescent dosimeters were installed in June 1983 around the plant fence-line and at control locations remote from the site.
Annual doses are determined f rom dose rate and occupancy time. Only locations on the northwest portion of the site boundary, bordering These Humboldt Bay, had dose rates measurably in excess of background. locations are accessible to the general public, by means of a footpath-which runs between the plant fence line and the bay. Occupancy factors for these locations have been taken from Table E-5 of Regulatory Guide - 1.109, for shoreline recreation. Table 2 provides calculated annual doses to the maximum exposed individuals from direct and scattered '~ radiation. J RESULTS AND CONCLUSIONS-Table 3 provides a summary of current (1981) annual doses to the maximum - exposed individuals as a result of operations at Humboldt Bay Power Plant. It is assumed in Table 3 that the same individuals receive the maximum doses from liquid effluents, gaseous effluents and direct and scattered radiation. It is also assumed that organ doses from direct and scattered radiation are equal to the annual doses calculated in Table 2,'from Pressurized Ion Chamber measurements. The highest whole body dose is 5.609 x 10~1 mrem to a teenager. The highest thyroid dose is 4.864 x 10-1 mrem to a teenager. The highest dose received by any other organ is 6.377 x 10-1 mrem to the liver of a teenager. . These values are significantly below the limits established by 40CFR Part 190. Due to the conservative assumptions used to calculate the dose and the minimal values derived, there is reasonable assurance that operations at Humboldt Bay Power Plant are in compliance with 40CFR Part 190 requirements. (
- - , - - - - _ . . . - - . . _ , , , _ - ~ - - . - - _ - _ _ -
- ~
s TABLE 1
.(. ,.
=
RESULTS OF HBPP Ei!VIROTEENTAL PADIAT10H SURVEY Exposure Rate Expcsure Rate Less (uR/hr') Background (uR/hr), location . 1 7.3 0.9 9.5 3.1 2 3 13.6 7.2 4 13.0 6.6 5 9.0 2.6 6 7.2 0.8 7 6.4 --- 8 6.6 -- 0.2 9 6.2 --- 10 6.4 , 11 7.2 0.8
-I 12 7.1 0.7 13 7.2 0.8 14 7.1 0.7 15 5.5 ---
16 7.0 0.6
.Arcata 6.4 4
k 2
' ' W
-d
*8"
+
+
WNW
- FIGURE 1
' s .
/
s- . s s. r sw '5 - s s s
' NNW t
' .,Q{h ' .., e g \
t
\l , 4 N \
cg = ',-. 1 ,p,,, 3 +' 'Ns 2
.=
N
// ~ 8.
ssw y\f3, i 'a, t .
.n <
-e c.,
i
\.
9 %, g ~. Mp E Wd F j' ,e ., N
\ .>s i ,>, '
a j I 9'f!s \v N. Nx i o ' 8 s
\ '\'N g i N
/
==
s / N; sis Q. , s
,/ N. 14 _m__ _
_ ,is
/ NE
_ _ _ _ _ _ _ _Ql _ _\ _ _ _ _ .i 2 io L______e ' _ ' EsE ENE Ji Af ssE SE E
W t G H W A Y I D I MAG. N -
3/ SITE PLAN - HUMBOLDT BAY POWER PLANT A
! *I+ PACIFIC GAS AND ELECTRIC CQ xeree.
- e' + DEPARTMENT OF ENGINEERING -
{ I e TABLE 2 Doses To Individuals From Direct And Scattered Radiation I Maximum Exposure Rate Above Background
= 7.2 uR/Hr Infant Child Teen Adult Occupancy Factor 0 14 67 12 (Hr/Yr)
Annual Dose
- -1 8.64x10-2 0 1.01x10 4.82x10
. (MREM) k k
r ,. , .. , f J J ) - TABLE 3 1981 SUM ARY OF ANNUAL DOSES (MREM) i BONE LIVER TOTAL THYROID KIDNEY LUNG GI-LLI BODY i LIQ. 0.000E+0 0.000E+0 0.000E+0 0.000E+0 0.000E+0 0.000E+0 0.000E+0 GAS 4.369E-3 4.356E-3' 4.351E-3 4.353E-3 4.352E-3 4.444E-3 4.350E-3 INFANT RAD 0.000E+0 0.000E+0 0.000E+0 0.000E+0 0.000E+0 0.000E+0 0.000E+0 TOTAL 4.369E-3 4.356E-3 4.351E-3 4.353E-3 4.352E-3 4.444E-3 4.350E-3 LIQ. 1.200E-1 1.342E-1 5.065E-2 4.161E-5 4.628E-2 1.274E-2 4.871E-2 l 4.354E-3 4.354E-3 4.489E-3 i GAS 4.393E-3 4.360E-3 4.353E-3 ~ 4.352E-3
- CHILD RAD 1.010E-1 1.010E-1 1.010E-1 1.010E-1 1.010E-1 1.010E-1 1.010E-1 TOTAL 2.254E-1 2.396E-1 1.560E-1 1.054E-1 1.516E-1 1.182E-1 1.541E-1 LIQ. 9.704E-2 1.513E-1 7.452E-2 4.022E-5 5.440E-2 1.583E-2 1.366E-1 GAS 4.389E-3 4.360E-3 4.354E-3 4.353E-3 4.354E-3 4.518E-3 4.356E-3 l
i TEENAGER RAD 4.820E-1 4.820E-1 4.820E-1 4.820E-1 4.820E-1 4.820E-1 4.820E-1 TOTAL 5.834E-1 6.377E-1 . 5.609E-1 4.864E-1 5.408E-1 5.024E-1 6.230E-1 l 1 1 l " 9.284E-2 1.471E-1 1.086E-1 4.390E-5 5.363E-2 1.304E-2 1.966E-1 ! LIQ. 4.356E-3 i GAS 4.382E-3 4.357E-3 4.354E-3 4.352E-3 4.353E-3 4.462E-3 l RAD 8.640E-2 8.640E-2 8.640E-2 8.640E-2 8.640E-2 8.640E-2 8.640E-2 l ADULT 1.836E-1 2.379E-1 1.994E-1 9.080E-2 1.444E-1 1.039E-1 24865E 1 TOTAL l i l - t ; t : I
a -- a .
. . s REFERENCES
+ 4
- 1. Title 10 Code of Federal Regulations, Part,20.
'i 2. Title 40, Code of Federal Regulations, Part 190. ,
- 3. $UREG-0543, " Methods of Demonstrating ' LWR Compliance With The EPA Uranium Fuel Cycle Standard (40 CFR Part 190)", February 1980.
- 4. Regulatory Guide 1.109, " Calculation of Annual Doses To Man From
- Routine Releases Of Reacter Effluents For The Purpose Of Evaluating ,
Compliance With 10 CFR Part 50, Appendix 1", Revision 1, October, 1977.
- 5. Humboldt Bay Power Plant Unit No. 3. " Report On Radioactive Effluent Releases And Waste Disposal", covering the period January 1 through June 30, 1981.
- 6. Humboldt Bay Power Plant Unit No. 3 " Report on Radioactive Ef fluent Releases And Waste Disposal", covering the period July 1 through December 31, 1981.
4 7. " Analysis of Compliance With 10 CFR50, Appendix 1 For The Humboldt
-. Bay Unit 3 Nuclear Plant", November 1976.
- 8. ANS1/ANS-6.6.1-1979, " Calculation and Measurement Of Direct And Scattered Camma Radiation From LWR Nuclear Power Plants", approved January 25, 197,9.
- 9. USNRC Branch Technical Position, "An Acceptable Radiological Environmental
( Monitoring Program", Revision 1, November 1979.
- 10. NUREG-0133, " Preparation Of Radiological Effluent Technical Specification For Nuclear Power Plants". October 1978.
l f 4
(' ' T3 PACIFIC GAS AND E LE C 'h EI-C ..Cr.y. O M PANY a b '.dk'd' l 77 BEALE STREET . S AN FRANCISCO. CALtFORNI A fs4106 . (415)781 4211 . twr 910-372-6587 September 8, 1983 Mr. John B. Martin, Regional Administrator U. S. Nuclear Regulatory Chrr=4asion, Region V 1450 Maria Iane, Suite 210 Walrut Creek, CA 945 % -5368 Re: Docket No. 50-133, OL-DPR-7 Humboldt Bay Power Plant Unit No. 3 Radioactive Effluent Releases and Waste Disposal
Dear Mr. Martin:
Enclosed is a copy of the linboldt Bay Power Plant Unit No. 3
" Report on Radioactive Effluent Releases and Waste Disposal" covering the period from January 1 through June 30, 1983. 'Ihis report is required by Section IX.I.3.a. of the limboldt Bay Unit No. 3 Technical Specifications, and 10 CER 50.36a(a)(2). Also enclosed are Quarterly Reports No. 86 and No. 87, "Enviremental Radiation Study in the Vicinity of linboldt Bay Power Plant". 'Ibese Quarterly Reports are for the quarters arvHng September 30, 1982 and Deamhar 31, 1982, respectively.
In the future, the Favironmental Radiation Study will be subnitted annually beginning with the submittal of the " Report on Radioactive Effluent Releases and Waste Disposal" for the period January 1,1984 throtsh June 30, 1984. 'Ihe Environmental Radiation Study will contain all data coupiled in calarvie year 1%3. Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope. l Sincerely, i
. Enclosures c'c: California Department of Health Services Radiologic Health Section h= ant Control Desk R. C. DeYoung, Director a f j50?Y?Y Office of Inspection and Enforcement
=*= 0 $j (3
s-PACIFIC GAS AND ELECTRIC COMPANY DOCKET NO. 50-133 - i ~ ' LICENSE NO. DPR-7 RADIOACTIVE EFFLUENT RELEASES AND WASTE DI.SPOSAL F1Rhh , . HUMBOLDT BAY POWER PLANT UNIT NO. 3, COVERING THE PERIOD JANUARY 1, 1983 THROUGH JUNE 30, 1983 This report summarizes the quantity of each of the principal radionuclides released to unrestricted areas in liquids and gaseous effluents and summarize radioactive waste disposal from January 1,1983 through June 30, 1983. This report is required by Section IX.I.3.a of the Humboldt Bay Power Plant, Unit No. 3, Technical Specifications. A. SUPPLEMENTAL INFORMATION
- 1. Regulatory Limits:
4 a. Fission and activation gases: The current license limits are 50,000 micro-Curies per seccnd for an annual average release rate and 500,000 micro-Curies per second for an instantaneous 1 release.
- b. Iodines: Refer to c. (Particulates).
- c. Particulates: The current license limit "for halogens and particulate material based on the isotopes present on the sample filters after 4E hours decay period" is 0.18
' micro-Curies per second.
- d. Liquid Effluents: 10CFR20.
- 2. Maximum Permissible Concentrations:
The concentrations used to determine allowable release rates or concentrations are as follows: ! a. Fission and activation gases: Not applicable,
- b. Iodines: 3E-10 micro-Curies per cc.
- c. Particulates (half-lives >8 days): 3E-10 micro-Curies per cc,
- d. Liquid effluents: 10CFR20, Table II, Appendix B. Refer to 1
Table C1 for the values used, based on the mixtures for each j quarter.
- -DCPP2 - 1. . _ ~
(,
- 3. Average energy:
Not applicable. - -
- 4. Measurements and Approximations of Total Radioactivity:
The methods used to measure or approximate the total radioactivity , in effluents and to determine radionuclide composition are as t follows: v
- a. Fission and activation gases: Due to the long decay time since
- operation (shutdown July 2,1975) no detectable releases of fission and activation gases can be expected. Accordingly, these radionuclides are not reported,
- b. Iodines: Charcoal cartridges are removed from the stack j- sampling system weekly and,.after 48 hour decay, are analyzed i for I-131 and 1-133 (Intrinsic Germanium detector). Due to the long decay time since operation (shutdown July 2,1976) no detectable releases of r.adioactive iodines can be expected.
Accordingly, these radionuclides are not reported. 4 c. Particulates: Filter papers are removed from the stack , sampling system weekly and, after 48 hours decay, are analyzed j for gross alpha (Internal Proportional Counter) and the - concentration of gama emitting nuclides (Intrinsic Germanium Cetector). All statistically significant peaks are identifed. Tre filters for each quarter are analyzed for radioactive 4 Strontium (all Sr-90 due to decay time). The error of the reported release values is estimated based on i.ncertainty in sample flow rate, stack flow rate, detector calibration, and typical sample counting statistics. t'. . Liquid effluents: Liquid waste batch samples were gama spectrum counted and counted for gross beta radioactivit'y. All statistically important peaks were identified. Quarterly composites of all batches were analyzed for gross alpha, Tritium and radioactive Strontium (Sr-90). The error of the reported release values is estimated based on uncertainty in sample volume, batch volume, detector calibration, and typical sample counting statistics.
- l. 5. Batch releases:
i a. Liquid: Number of batch releases: 32 (A total of 4,493 gallons of i 1) laundry waste and 92,930 gallons of treated waste tank discharge). DCPP2 ' 2
. e i
5.02E3 minutes. Total time period for batch releases:
- 2) 1.57E1 minutes.
Average time period for a batch release:
- 3) ,
4.50E2. minutes. Maximum time period for a batch release: 4) 1 9.00E0 minutes. Minimum time period for a batch release: 5) Average stream flow Not applicable during(Discharge periodsisof intorelease of ef um
- 6) into a flowing stream:
Humboldt Bay).
- b. Gaseous: None.
- 6. Abnonna'l releases:
- a. Liquid:
None.
- 1) Number of releases:
None. 2) Total activity released:
- b. Gaseous:
None .
- 1) Number of releases:
None. 2) Total activity released: B. GASE0US EFFLUENTS and the detectable The monitoring systems associated with ort the period. emergency con liquid radwaste system vents to atmosphere re indicated that n releases of radioactive gases occurred duringdethe rep250 via the Because quarterly checks of the HEPA filters on the vents we satisfactory, only gaseous radioactive waste releases ma foot stack are reported. ffluents i Table B-1 summarizes the total quantities of radioactive released by quarter.of the-nuclides determined to be released. / l C. LIQUID EFFLUENTS k nd the plant discharge monitor Analysis of weekly composite samples from t occurred the plant inta e effluent canal and monitorinn by the liquid rad l during the report period. liquid effluents
- Table C-1 summarizes the total quantities of radioactiv released by quarter.the nuclides determined to be released.
1
PRELIMINARY NOTIFICATION OF EVENT OR UNUSUAL OCCURRENCE--PHO-V-83-2 Dats: 6/27/83 [ l 'This'prelininary n:tificaticn constitutes EARLY n:tice of ev:nts of POSSIBLE s'dCat afety er public interest significance. The infonnation is as initially received without verification or evaluation and is basically all that is known by IE staff on this date, k .:ILITY: Pacific Gas and Electric Company Licensee Emergency Classification: Humboldt Bay Nuclear Power Plant (Unit,3) Docket Nos. 50-133, License DPR-7 Notification of Unusual Event i Eur.eka, California Alert -
SUBJECT:
LICENSEE ANNOUNCES INTENTION TO DECOMMISSION Site Area Emergency HUMBOLDT BAY NUCLEAR POWER PLANT General Emergency x Not Applicable At 8:30 a.m. PST the licensee's upper management called the Region V office to state PG8E's intention to decomission the Humboldt Bay Nuclear Power Plant. The licensee's
.Vice President for Nuclear Operations met with Region V personnel at 11:00 a.m. the same day to explain the reasons for this decision and the probable future actions by PG&E.
The licensee's decision is based on an economic study which indicated it would require between $241,000,000 and $446,000,000 to restart the facility by 1998 and that replacement Power costs are lower than anticipated, with the result .that it should be cheaper to generate or purchase power at other facilities. The licensee's personnel expect to apply fer a " possession only" license and to subsequently place the facility in custodial SAFSTOR [ fcr 30 years. This will ~ require licensee Eersonnelhove the fuel in the reactor to the spent fuel pool, submit a detailed decommissioning plan, decontaminate and ship wastes to a disposal facility, ship the spent fuel to a federal spent fuel disposal facility, and to continue radiation monitoring, environmental monitoring, and security programs. At this time the facility has been shut down since July 1976 and the decay heat from t ( ' 9 spent fuel is negligible. t. ine licensee's personnel stated that a press release would be made near the facility, (Eureka, California) at about 2:30 p.m. PST and that' they were separately informing NRR in Bethesda, Maryland. Region V will coordinate with Headquarters.and NRR to develop NRC resource requirements and to evaluate the licensee's decomissioning plans. Media . interest is expected. The licensee plans to issue a news release at 2:30 p.m. ! PST in Eureka, California. Region V (San. Francisco) received notification of this occurrence from the licensee at about 8:30 a.m. on June 27, 1983. This information is current as of 1:30 p.m. on June 27, 1983. CONTACT: D. F. Kirsch P. J. Morrill 463-3723 463-3740 { i . DISTRIBUTI N: g f y , p l H St. Y tlT' MNBB'/:Yr Phillips Y!d E/Wy_!I/t Willste vit7 Air Rights V:s9 Mail: Chaiman Palladino EDO 1* NRR IE NMSS ADM:DMB Com. Gilinsky PA OIA RES DOT: Trans i
% n. Ahearne MPA AEOD Only g n. Roberts
. ..a. Asselstine ELD / // /
Regions:I g 1g,2K ,f SECY INPO - NSAC / ACRS Licensee: CA (Reactor Licensees) REGION V: ORM 21 PDR R (revised 3/14/83) CMMMN l g ?sident Inspector .
,., j,_ W 7 r.ggy
J/' / S.3 [f m%), UNITED STATES
, NUCLEAR REGULATORY COMMISSION '
! * , ., y ,;j
; ; WASHINGTO N, D. C. 20555
/
July 7,1982
~
Mr. Ron Guenther 29900 Highway 20 Fort Bragg, California 95437 Deai Mr. Guenther: This is in response to your letters dated January 16, 1982 and June 8,1982. Those letters requested that the Humboldt Bay Nuclear Power Plant be decommissioned. I have considered the information contained in your letters and letters received from others on the same subject. Based on this information and on the NRC requirement that the plant remain in a shutdown condition, I have determined that decommissioning of the Humboldt Bay Plant is not warranted. Accordingly, I have denied your request. The decision I have reached is set forth in the " Director's Dec'ision" dated July 7,1982 . A copy of that decision is enclosed for your information.
- I appreciate your interest in the safety of the Humboldt Bay plant and will continue to require that the public health and safety is adequately protected.
Sincerely,
,4w z?L Harold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosure:
Director's Decision. cc: See next page e e e
.tj '(j ts k 3 "
. s
/-f e
!. pt 2rr - g ,
.LO7l 8 '$
?. , , ,
)
Mr. Philip A. Crane," Jr. Pacific Gas & Electric Company 77 Beale Street, 31st flocr San-Francisco, California 94106 cc: . Mr. James Hanchett
-Public Information Officer Michael R. Sherwood, Esq.
Region V - IE Sierra Club Legal Defense U. S. Nuclear Regulatory Commission Fund, Inc. 1990 N. California Boulevard 2044 Fillmore Street Walnut Creek, California 94596 San Francisco, California 94115 Mr. Eric W. Hedlund Linda J. Brown Esquire
., Humboldt Co' u nty Board of Supervisors Donohew, Jones Brown & Clifford County Courthouse 100 Van Ness Avenue, 19th Floor ,
825 Fifth Street San Francisco, California 94102 l Eureka, California 95501 '. Dr. Perry Aminoto. Bruce Norton, Esq. . Department of Conservation
' 3216 N. Third Street, Suite 202 Division of Mines & Geology I-Phoenix, Arizona 85012 1416 9th Street. .toom 1341 1
Sacramento, California 95814 Friends' of the Earth Humboldt County Library ATTN: Andrew Baldwin 636 F Street 124 Spear Street Eureka, California 95501 San Francisco, California 94105 California Department of Health ATTN: Chief. Environmental - Radiation Control Unit
, Radiological Health Section 714 P Street, Room 498 -
Sacramento, California 95814
- U.S. Environmental Protection -
Agency Region IX Office i- Regional-Radiation Representative 215 Freement Street ,;- San Francisco, California 94101 ,( - a ,. '1 Robert H. Engelken , Regional Administrator, Region V U.S. Nuclear Regulatory Commission i, 1990 N. California Blvd., Suite 202 .
. Walnut Creek, CA 94596 '
\ . .
-_.__,_.y---___- .y - __-.-,-.,,,-3y- - - , , - . - - , - - . _ _ _ , , . ,
_,_,,..___--..,.cw
=. . .-
O-
, , i . s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Harold R. Denton, Director In the Matter of ) ,
)
PACIFIC GAS & ELECTRIC C0tiPANY ) (Humboldt Bay Power Plant) ) Docket No. 50-133 f
- DIRECTOR'S DECISION UNDER 10 CFR 2.206 Mr. Ron Guenther by letter dated January 16, 1982 to the Atomic Safety and Licensing Board requested that the Humboldt Bay Power Plant, Unit No. 3 be decommissioned. That letter was resubmitted to the Director of Nuclear
; Reactor Regulation on February 20, 1982. Notice of receipt of this request was published in the FEDERAL REGISTER on April 4,1982 (47 FR 14632).
Mr. Guenther submitted additional infomation to support his request by letter dated June 8,1982. - Mr. Guenther asserts a number of reasons why the Humboldt Bay Plant l, should be decomissioned. After considering the request, for the reasons set forth below, I have concluded that the maintenance of the Humboldt Bay Plant in its present status does not adversely affect the public health and safety and therefore no basis exists to require the decommis-
; sioning of the Humboldt Bay Plant at this time. Accordingly, I have deter-mined that Mr. Guenther's request must be denied. ; , I.
i On July 2,1976, the Humboldt Bay Plant was shutdown for replacement of some of the fuel in the core. By Order dated May 21, 1976, the' NRC required that before resuming operation, the Pacific Gas and Electric Company (the
~
licensee) complete certain activities. The licensee was required to upgrade as necessary, the seismic capability of safety-related equipment (e.g., the reactor coolant pressure boundary) to current requirements, and to resolve
~
. ( . 2 >
00-82-7 more recent seismic concerns having to do with earthquake vulnerability that had arisert since the time the operating license was issued on August 29, 1962. The licensee has replaced the fuel in the core, undertaken extensive geological investigations, and completed some plant modifications. The question of future operation of the Humboldt Bay Plant is before a Licensing Board which on February 16, 1982 issued a Memorandum and Order which accepted the staff's conclusion that the Humboldt Bay Plant in its present shutdown condition poses no undue risk to the health and safety of the public. In addition, the Board established a time table for the licensee to decide whether it would resume operation of the plant or deconunission it. All of the issues which Mr. Guenther cited in his letters had been . previously considered by the staff. The letters contained no new information or safety concerns unknown to the NRC. The seven issues raised by - Mr. Guenther's letter that are within NRC jurisdiction are discussed in detail below. The other issues regarding economic impacts on ratepayers of a decision to decommission do not lie within the purview of the NRC and, therefore, i are not addressed in this decision. 1.
, Plant Design and Operating History i
Mr. Guenther's letter alleges that '. t; "The subject nuclear power plant is poorly and inadequately designed' i for safe operation, and has a long history of operating and safety failures deriving directly from design deficiencies." As noted above, the Humboldt Bay facility is presently shutdown. The NRC staff is not aware of previous problems of a type which would
- cause concern as to the ability of the licensee to maintain the plant in its present safe shutdown condition. The enclosed Staff Affidavits (Enclosure 1), originally submitted to the Atomic Safety and Licensing Board on November 19, 1981, describe the current status of the Plant and its rac.ent inspection history.
. . . . . . . . - . - _ = _ - _ - - -
. t '
3 - D0-82-7 Before approving the resumed operation of Humboldt Bay Power Plant Unit No. 3, the NRC staff will require correction of significant design deficiencies. The operating history of the plant will also be considered
, prior to approving resumed reactor operation, to the extent that the history is pertinent, considering the elapsed shutdown interval of greater than five years duration. The staff considers the plant design, as well as its operational record, to be acceptable for the present shutdown condition of the plant.
- 2. Seismic Design Mr. Guenther's letter also alleges that "Three earthquake faults have been discovered within 4,000 feet of the reactor, and appropriate design safety measures were not incorporated
- into either the reactor's design or construction. The subject plant
- does not conform to the Nuclear Regulatory Commission seismic standards.
The cost of bringing the subject plant into compliance with these standards could exceed $300 million, compared with estimated decommission-ing costs of $35 million. Decommissioning is therefore the preferred economic alternative." 1
- The Humboldt Bay Plant was issued a provisional operating license in 1962 4
based on seismic design practices acceptable at that time. In the course of
' review associated with changing the provisional operating license to a full term i
operating license in 1969, questions arose which resulted in further seismic studies at the site. During the course of this seismic reevaluation as the
.l regional' geologic picture was developed in greater detail, the confidence that the original plant design could withstand all postui.ated seismic events declined.
For this reason the geologic / seismic investigations and the set.smic design i' upgrading were required to be completed prior to restart from the 1976 refueling
~
putage. Therefore, seismic design inadequacy has already been identified as a The deficiency that must be corrected before approval of resumed operation. G 1 0
*e e h*ee '* ,
r.
* \ p 4 D0-82-7 cecision of whether to incur the costs of implementing whatever design changes are deemed necessary or decommission the facility is one which the company and the state ratesetting body must make. ' Such economic decisions are.not within the purview of the NRC.
Mr. Guenther's letter alleges that "The subject nuclear power plant's operating record is among the worst in the history of nuclear power. The public has been presented no convincing evidence that this sorry and irresponsible operating history will, or even can change for the better. The latest evidence ir.dicates that the utility will continue to operate the subject plant in a negligent, irresponsible, and unsafe manner." Humboldt Bay. Power Plant Unit No. 3 has been shutdown since July 2,1976. Since that time, the standard inspection (surveillance) program for a shutdown reactor has been performed by the NRC regional office at the Humboldt
~
Bay Nuclear Power Plant. This inspection consists of inspections of design changes and modifications, activity of the Onsite Review Committee, QA program, overall training program, fire prevention ano protection, sur-veillance of equipment during extended shutdown, security and material accountability, radiation protection program (as reported in news clipping attached to Mr. Guenther's June 6,1982 letter), transportation of radioactive materials, and radioactive waste management. Recent inspections have not lt revealed any major problems at the plant (See attached affidavit of i; \ l TolbertYoung). Before approving resumption of, operation, the staff will review this operating record, the operational history of .the plant prior to 1976, and other considerations to detennine that the utility and l' l
- operating staff are capable of safely operating the ' plant. The staff
( considers, based on our review of the operation of the facility since i L 1976, that the staffing and servicing of the plant is adequate for its present shutdown condition.
. (
5 00-82-7
- 4. Disregard for Public Health and Safety Mr. Guenther's letter alleges that *
"The utility has failed to comply with an Atomic Safety and Licensing Board
. order to reveal how the company expects to bring the subject power plant up to current Nuclear Regulatory Commisssion Seismic standards. This latest example of the utility's continuing reckless disregard for the public health and safety indicates plant decommissioning as the only practicable solution for problems of public protection" The Atomic Safety and Licensing Board has ordered (Memorandum and Order dated February 16, 1982) that the licensee report, at a future date, plans for long term use of the Humboldt Bay Plant, and in the meantime submit every three months, status reports to the Board. The licensee has submitted these reports, and the Board has not found the licensee's responses unacceptable.
The staff does not regard the licensee's response to the Board Order as exhibiting any failure to comply nor as evidence of an actitude of dis- ~ regard for public safety. In summary, the staff does not belfeve that the conduct of the utility during the proceedings before the Board represents
. a disregard for the public nealth or safety.
r
- 5. and 6. Economic Considerations Mr. Guenther's letter alleges "The subject power plant is one of the oldest commercial nuclear powei-plants under the Board's jurisdiction. It went' on line in 1963.
Approximately 1/2 to 1/3 of the plant's life expectancy has elapsed. Decommissioning at this time would save future ratepayers substantial' expenditures before embrittlement, increased residual radioactivity, and other safety problems become acute, and decommissioning costs rise dramatically," l i
l ', . ( I
~
6 00-82-7 and'also, "As the utility continues to engage in delaying tactics whic'h prolong the process of solving public protection problems, it continues to maintain and to protect the subject plant. Since 1976 the costs of maintenance have been approximately $15 million. Decomissioning the the plant would eliminate at least maintenance problems for core loadings, and would cut the necessary costs of plant surveillance until the plant could be either dismantled and moved to its final repository, or entombed in situ." As previously noted, the impacts on ratepayers or shareholders of a utility's decision to operate or decommission its facility is not within the purview of the NRC.
- 7. Waste Disposal Mr. Guenther's letter alleged that "No permanent facility for safely disposing of the nuclear wastes-deriving from the operation of the subject plant exists at this time.
; This would include the approximately 35 tons of high-level waste now being stored at the plant site at substantial risk to the public health and safety in the area, downwind, and downcurrent from the site."
The Department of Energy (DOE) is responsible for developing the methods and technology for the permanent cisposal of high-level radioactive waste in a Federal repository and for submitting a license application for a potential repository. DOE is currently studying the feasibility of high-level waste disposal in deep geologic media. The Nuclear Regulatory Comission (NRC) , has promulgated licensing procedures for disposal, of high-level wastes in geologic repositories and has published proposed technical criteria. In its present shutdown condition the Humboldt Bay Plant is not gbnerating additional radioactive waste. The staff considers that the . health and safety of the public is adequately protected from the radioactive waste presently stored at the Humboldt Bay plant. 4 y .
(
. l
. 7 00-82-7
- 8. Population Density -
Mr. Guenther's latter alleges that
" Human population densities exist only a very short distance from the subjectfeet 1,500 plant site.
from theAs examples, heavily travelled Highway 101 is only reactor.
- There exists a nearby residential canmunity,
~ . beginning only 1/4 mile from the plant. In case of accident, release of radioactisity from the plant would seriously endanger human life in the area. Additionally, cumulative losses of life could occur in areas downwind and downcurrent from the subject site."
The consequences and types of accidents are greatly diminished because of the present condition of the plant. Staff analysis has concluded that Humboldt Bay fuel h'as decayed sufficiently that air cooling is adequate to preserve fuel cladding integrity. Therefore, measures to assure core cooling or mitigate loss of coolant consequences are unneces'sary. Due to the long period since the reactor last operated, mobile radioactivity has' decayed very significantly. - Fopulation density was considered in the original licensing of the Humboldt Bay Plant, as 'well as the possibility of population growth and redistribution. For the present shutdown condition of the plant, the population around the plant is adequately protected. The staff will con-sider changes in population density near the Humboldt Bay Plant before approving resumed plant operation.
- 9. Proximity of Humboldt Bay i
i
, Mr. Guenther's letter alleges that .
i ;, "Humboldt plant site. Bay is immediately proximate to the subject nuclear power Safety problems inherent in the plant's radioactive dis-
- charges on sealife, and on the human foodchain, have not been effectively recognized, evaluated or dealt with."
O 6
9 , . ( )
'.'- 8 00-82-7 Before approving the resumption of operation for the Humboldt Bay Plant, the staff will Derform any evaluations of the environmental effects of the operation of the Humboldt Bay Plant which might be reouired. As discussed in the re:ponse to Item 8, the significance of accidents is reduced by the present condition of the plant. In the plant's present shut-down condition, plant radioactive discharges are much less than when the plant was operating and are well witnin NRC regulatory limits. The releases are considered acceptable.
II. Based on the foregoing I have determined that the requested decom-missioning of the Humboldt Bay Power Plant, Unit No. 3 is not warranted. The health and safety of the public are adequately protected from the facility in its present shutdown condition. All safety issues pertinent to an operating reactor will be resolved before future operation of the Humboldt Bay facility is permitted. Consequently, Mr. Guenther's petition
- for deconmissioning of the Humboldt Bay facility is denied.-
A copy of this decision will be placed in the Commission's Public { , Document Room at 1717 H Street N.W., Washington, D.C. 20555 and in the local public document. room at the Humboldt County Library, 636 F Street, Eureka, California , 955%; . . 1 Additionally, a copy of this decision will be filed with the Secretary of , the Commission for review by the Commission in accordance with 10 CFR t
-. % u n . ,-;-. n a n
~
t n
, . 9 00-82-7 Section 2.206(c) of the Commission's regulations. As provided in 10 CFR 2.206(c), this decision will constitute final action of the Commission twenty-five (25) days after the date of issuance, unless the Commission on its own motion institutes the review of this decision within that time.
MNk Harold R. Denton, Director Office of Nuclear Reactor Regulation Dated at Bethesda, Maryland this 7th day of July 1982. 6 l l; 1' I . l l l l (
+
. / e,, u:;lTED STATES Enclosure 1
. ! W. '
// n "U0i FAli REGUI ATORY COTAMISSION i
1 9' I v;..smNG TON, D. C. 20555 1 ; 3.:,';/ ' bf/ .f
,, g m.s /
November 19, 1981 i .
! Richard M. Lazo, Esq., Chairman Gustave A. Linenbe'rger Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Re{ulatory Commission Washington, DC 20555 Washington, DC 20555 Dr. David R. Schink Adninistrative Judge a Department of Oceanography 3
- Texas A & M University a College Station, Texas 77840
! In the Matter of
- PACIFIC GAS AND ELECTRIC COMPANY (Humboldt Bay Power Plant. Unit No. 3) l, Docket No. 50-133 i
jj
Dear Administrative Judges:
! In its Memorandum and Order of October 20, 1981, the Licensing Board I directed the Staff to provide answers to eight questions within thirty days of the date of service of the Order. Order at 2-3. This letter -
J regarding question 1 and the accompanying affidavits of Vernon Rooney, Project Manager, Tolbert Young, Jr., Office of Inspection and Enforcement,
, , and Ina Alterman and Jeffrey K. Kimball, Geosciences Branch, variously
'l- addressing the balance of the questions constitute the Staff response. Question 1: What regulatory requireinents apply to a plant in cold shutdown mode?" The regulations, with few exceptions.M do not contain express refer-ences which indicate their applicability to a plant in colc shutdown. 1 Generally, Part 50 contains the requirements for normal operation and certain transient conditions. In the absence of any express exclusion
; y Appendix R focuses on the protection of structures, systems and components associated not only with achieving safe shutdown but also maintaining safe shutdown from the probability and effects of fires.:
The term " safe, shutdown" as used in Appendix R to 10 C.F.R. Part 50 applies to both' hot and cold shutdown. Appendix R(I). In addition, section 50.54(q), for example, requires a licensee " authorized to possess and/or operate a nuclear power reactor" to have emergency . plans which meet the standards in i 50.47(b) and the requirements in Appendix E to Part 50. u w
+ +-e -- --sd --e.->,--qw --wyw p -1's- - - - e- gwyy+-eye-e---Tw-e*-+ - w-w-eeeewcw.--+-y,s-a.--+-we-----.me-w*-.-.+p-,-.u- - ---w.+. W--<-.-,-- w-ee
s . _ 4.,.--_ < ,a aw A at -.
, i o o -2 i in the regulations of cold shutdown and because it is one of the five modes of operation defined by the NRC and in a facility's license, the <
regulations that apply to a plant in normal operation will also apply to a plant in cold shutdown. Therefore, the provisions of 10 C.F.R. Parts 20, 30, 40, 50, 51, 55, 70, and 73, which are not expressly limited by their tenns, are applicable to plants in a cold shutdown operating mode. However, with respect to a facility whose license is to be limited to shutdown condition, the various provisions applicable to normal l operation, transients and accidents should be construed as relating to the shutdown condition (i.e., normal shutdown conditions, transients i affecting the shutdown condition, accidents and abnonnal occurences as they affect the shutdown condition). For example, those provisions requiring consideration of LOCA conditions would then consider the effect of loss of coolant under conditions of a cold depressurized primary system and a core with essentially no decay heat. Thus, in many cases very little , if anything, is needed to demonstrate compliance. For example, little would be needed to show ap
- against pipe whip (General Design Criterion 4)propriate when all fluids protection are cold i and depressurized. Rooney Affidavit.
The licensee must also comply with any conditions or requirements imposed by Order, its license and technical specifications. Humboldt Bay has not received Orders regarding the implementation of NUREG-0578 and NUREG-0737 standards and modifications. Sincerely,
/
[.,([ ~, 34((L II ( Steven C. Goldberg Counsel for NRC Staff cc: w/ enclosure. Service List G 4 k 1 a e 4
' "* ae * * , e <= see.ee eemo spee*= s ete e s e e e, e ,e, e ape .
, _ , , , ,, . _ ,_ __,,m - - - - . , _ _ - - _ , _ - , _ _ , . , _ - - , _ - - . - , _ _
~
a UNITED STATES OF AllERICA NUCLEAR REGULATORY C0t@t!SSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD -
. a .
,In the Matter of PACIFIC GAS AND ELECTRIC COMPANY ) Docket No. 50-133 (Humboldt Bay Power Plant,.
Unit No. 3) ) AFFIDAVIT OF VERNON ROONEY RESPONDING TO MEMORANDUM AND ORDER OF OCTOBER 20, 1981 7 I, Vernon Rooney, being duly sworn state the following:
- 1. I am employ'ed by the U.S. Nuclear Regulatory Commission as a Senior Project Manager in the Division of Licensing, Office of Nuclear Reactor Regulation. A copy of my professional qualifications are
~
attached and are true and correct to the best of my knowledge and belief.
- 2. I am the project manager assigned to the Humboldt Bay facility.
- 3. -In its Nemorandum and Order of October 20, 1981, the Board directed the Staff to answer questions listed on pages 2-3. The Staff's
, response to questions 2, 3, 5-8 are provided below and in the attached affidavit from the Office of Inspection and Enforcement.
- 4. Question 2:
. Are the applicable regulatory requirements currently bein'g met by , Licensee? .
. With respect to a facility whose lice'nse is to be limited to shutdown condition, the various provisions applicable to nomal operation, ,
-h s
. . . . . . ._ _ ~ . . . ._ ._ . - - _ . _ . - . . . . - . . .
. ( )
2-transients and accidents should be construed as relating to the shutdown condition (i.e., normal shistdown conditions, transients affecting the shutdown condition, accidents and abnomal occurences as they affect the ' shutdown condition). For example, those provisions requiring considera-tidn of LOCA conditions would then consider the affect of loss of coolant under conditions of a cold depressurized primary system and a core with essentially no decay heat. Thus, in many cases very little, if anything, is needed to demonstrate compliance. For example, little would be needed to show appropriate' protectio'n against pipe whip (General Design Cri-terion 4) when all fluids are cold and depressurized. Based on review of correspondence with the licensee and the results of surveillance conducted by the Office of Inspection and Enforcement (See attachment 1), the staff is aware that applicable regulatory requirements
. are not being met in the following areask (1) 10 C.F.R.150.46 and Appendix K (ECCS). 10CFR550.46(a)(1) states that ECCS cooling perfomance shall be calculated in accordance with an acceptable evaluation model. Appendix K sets forth required model features. The licensee has not perfomed ECCS analyses for Humboldt Bay using currently approved ECCS models and, therefore, is not technically in compliance with the noted regulatory requirement.,
L I If Exemptions have been granted by the Staff under 10 CFR i 50.12 for the following. An exemption to the containment integrated leak i rate test requirements of 10 CFR Part 50, Appendix J, III(A) was -
- granted on
- July.13,1979. An exemption to the requirements for l operator training in 10 CFR Part 55, Appendix A,13a to include ten reactivity control manipulations every two years was granted on January 11, 1978. An exemption to the requirements of 10 CFR 673.55 relative to implementation dates was granted'on March 16, 1978.
- ( , n However, despite the absence of required calculations, emergency cooling is not required to remove fuel decay heat. Staff studies show that Humboldt Bay fuel has decayed sufficiently that air cooling is adequate to preserve cladding integrity. Therefore, measures to assure core cooling or mitigate loss of coolant consequences are unneccessary.
(2) 10 C.F.R.150.48 and Appendix R (Fire protection). Section50.48(a) requires a fire protection program that satisfies Criterion 3 of Appendix A to 10 C.F.R. Part 50. Section 50.48(b) states that Appendix R establishes fire protection features required to satisfy Criterion 3. Aspendix R requires a fire hazards analysis and certain fire prevention features. These have not been provided for Humboldt Bay, Nevertheless, the reactor is fully shutdown, with measures to assure continued shutdown as discussed in paragraphs 8 and 9 below. The mechanisms which maintain rod insertion would continue to function in event of fire. Protection of equipment to assure the capability to shutdown is unnecessary. Fire protection for core cooling systems is not needed because air cooling is d
. adequate. Due to the long period since shutdown, mobile radio-activity has decayed very significantly. The Staff, therefore, , , believes that in all cases the public health and safety is being - protected, despite the fact that the licensee has not complied with ,
Appendix R to 10,C.F.R. Part 50. ! ( l
i i 4 (3) 10 C.F.R. Part 50, Appendix A. Criteria 2 and 3. Criterion 2 requires design to withstand the effects of earthquakes. The
~
Humboldt Bay plant does not meet this criterion. The Staff has considered the seismic capability of equipment important to safety in 'the present shutdown condition of the plant and found it adequate to assure the continued protection of the public health and safety. Criterion 3 requires fire protection design, which is not provided at Humboldt Bay, as discussed above.
, 5. Question 3:
Has the Staff given consideration to the question of whether the exceptionally long shutdown of Humboldt Bay Unit No. 3 might give rise to the potential for significant safety problems? What unusual problems might arise? . Yes, the Staff has given consideration the this question. See answers to questions 5, 6, 7, and 8 for potential problem areas. I The staff concluded that in all cases the public health safety is adequately protected.
- 6. Question 5(a):
What physical security measu,res are currently in force? Based on the requirements of 10 CFR 50.34(c) and 10 CFR Part 73
. (1976) and guidance provided in AEC Regulatory Guide 1.17 - 1973,
" Protection of Nuclear Plants Against Industrial Sabotage" and ANSI
.' N18.17 - 1973, " Industrial Security for Nuclear Power Plants", the .
licensee submitted the " Pacific Gas and Electric Company Humboldt Bay Power Plant Security Plan", Revision 0 dated March 12, 1974,
(. I
.s.
Revision 1 dated April 14, 1975 and Revision 2 dated November 16, 197.6. Briefly, the current security program contains:
- 1) Designation of three areas within the owner controlled area at which access to the plant is controlled (Restricted Area, Protected Area and Inner Security Area). ,
, 2) Surveillance and intrusion detection capabilities through the use of guard patrols, closed-circuit television and intrusion detection systems.
- 3) Personnel access controls ranging from vehicle access control at the Restricted Area to searches for weapons, explosives, etc., and badging of" personnel at the Protected Area.
- 4) Redundant communication capabilities to local law enforcement agencies to assure assistance can be summoned should the need 7
arise.
- 5) Personnel selection, screening an'd appraisal programs to detect aberrant behavior or other characteristics which could be a detriment to plant security.
- 6) Periodic training progr'ams for plant employees to make them aware of their roles in plant security and the security procedures they are required to meet.
i
- 7) Periodic contract security force training program to provide ,
specialized , training and requalification of all guards in the physical security program and procedures at' the site. i
. - . . . - . - ~ . . . . . .
. L' '
. Question 5(b): -
What was the date and nature of the last change to the physical security procedures? , The most recent change was Revision 2 of the " Pacific Gas and Electric Company Humboldt Bay Power Plant Security Plan" dated November 16, 1976. This revision was submitted to clarify and consolidate information regarding implementation of physical security measures indentified in the licensee's letters of July 22, 1975 and August 6, 1975. - Question 5(c): What changes are planned between now and the end of CY 19827 (Assume no change in operational status) Based on an exemption frdn the requirements of 10 C.F.R. i 73.55 issued by letter dated March 16, 1978 to Pacific Gas and Electric Company from the Staff, we do not anticipate any regulatory required
', - changes to the Humboldt Bay security plan between now and the end of CY 1982.
I 1 7. Question 6: What surveillance is being routinely performed by I&E7 What was date and nature of last change in routine surveillance? What changes are planned between now and end of CY 1982? What non-routine surveillance has been performed? What were the results
- of surveillance efforts in 1980, 19817 (Assume no change in operational status)
The standard inspection (surveillance) program for a shutdown '. reactor is being ' performed at the Humboldt Bay Nuclear Power Plant. s This inspection consists of inspections of design changes and
I
,' . ('
mod'ifications, activity of the Onsite Review Committee,QA program, overall training program, fire prevention and protection, sur-
~
veillance of equipment during extended shutdown, security and material accountability, radiation protection program, transportation of radioactive materials, and radioactive waste canagement. These activities are inspected annually except when demonstrated satisfactory performance justifies reducing the O frequency to once per 18 months. In addition, licensee event ' reports, instances of noncompliance, and various other areas identified by other NRC offices are inspected as required. Twenty percent of the inspector's time is used to inspect areas of his own
~ '
choosing. The last change in routine inspection occurred when the reactor was. shutdown on July 2,1976, at which time operational aspects of
, inspection were scheduled at a reduced frequency consistent with the operational status of the facility and allocation of the NRC's resources, resulting in the program described above. There have been no other changes in inspection except for implementation of the i Revised Inspection Program (NUREG-0397) and the general upgrading
,C and refinement of existing programs. No changes in the inspection , l program between now and the end of CY 1982 are anticipated. One
- nonroutine inspection was performed (post-earthquake inspection);
- none are planned., Inspection efforts in 1980 and 1981 revealed
~
three infractions, one deficiency and one violation-severity level V. See Attachment 2. 4 i
' ~ ' - -
.L. :: : :*:L . T:: .. : _
(.' 8
- 8. Question 7(a):
What is status of facility, including components and systems that are routinely operated; and including location and conditions of storage of all new, partially used, and spent fuel? ~ Ilumboldt Bay Power Plant, Unit No. 3 is in the rold shutdown condi-
, tion. The master reactor switch is locked in the COLD SliUTDOWN mode which removes electric power from the control rods, all of which are fully inserted. Without electric power the rods cannot be withdrawn. The key to the master reactor switch is in the locked key cabinet, and the key to the key cabinet is in the possession of ci the Shift Foreman. Components and systems that are routinely operated include the reactor cleanup system, the emergency boration system, the liquid radioactive waste processing systems, the refueling building ventil'ation system (including the gas treatment system), nuclear instrumentation as required by the license, and the radiation monitoring system. The core is fully loaded with 140 partially irradiated assemblies and 44 new assemblies stored under water. The spent fuel pool contains 250 spent fuel assemblies stored under wa'ter. Thirteen new fuel pins,'but no assemblies, are
!i stored in air in the new fuel storage vault. The reactor vessel i j; head is in place and the shield plug is installed. l
- 9. Question 7(b):
! What is currently being done to maintain fuel integrity and assure its safety with respect to security, criticality and themal
- stability? -
The safety of the fuel is maintained by the following measures: ! t l l r l
. L> >
i ; .
. g.
a) with respect to security, the licensee is in compliance with its 1976 Security Plan and is audited against this plan (see l' ~ answer to Question 5). b) With respect to criticality, the rods are fully inserted with the master reactor switch locked in the COLD SHUT 00WN mode (as discussed above). In addition, control rod power is deenergized at various other locations. The liquid poison l system is available for backup criticality control of the reactor core if needed. Criticality in the spent fuel pool is avoided by the design of the spent fuel storage racks and the
. absence of large amounts of highly enriched fuel. ,
c) With respect to thermal stability, the irradiated Humboldt Bay . , fuel is maintained w'ater covered. The staff has concluded that the fuel cladding would remain intact with only air cooling, if there were complete loss of water. 4 t
- 10. Question 8(a):
Describe physical and preventive maintenance being performed to assure continued integrity of safety related components. Physical and preventive maintenance is performed as necessary to maintain as operable the systems described in the answer to I i
;- question 7. Technical Specification requirements for surveillance testing during cold shutdown include requirements for the fire protection system, the gas treatment system, the ventilation system,
- the radiation monitoring system, and the security systems.
r I
** *m e e. sew- mm =see p pem4 we. ....w., . , ,,,
- ~. --,.-....a -,..,w , , , - -- , - , , . - -
( .
')
- 11. Question 8(b):
What is size, makeup (by discipline) and duty cycle of standby crew? The Humboldt Bay Power Plant, Unit 3 is at a site which alsd acconmodates two additional fossil units (Units 1 and 2) in addition
' to 'tSc mobile emergency power generating units which are frequently used to provide peak load generating capacity in the absence of the
- shutdown Unit 3. The crew staffing the site operates all generating units, and is therefore not really a standby crew. The normal minimum 7 man operating shift crew is maintained at all times. Each
^ ^ of the four shift crews have the following minimum personnel: Position Qualification Assignment 1 Shift Foreman Sr. R"eactor Operator License entire plant 1 Control Operator Reactor Operators License Unit 3 only 1 Sr. Control Operator Reactor Operators License Units 1, 2 and 3
.1 Control Operator No license Units 1 & 2 1 Auxiliary Operator No license Units 1 & 2 4
2 Auxiliary Operators No license entire plant
; The Senior Reactor Operator'and Reactor Operator Licenses have been maintained current with the exception of startup experience , ; requirements (which are not pe'rtinent for a shutdown condition). The
- f. shift crews rotate between day shift, swing shift, and graveyard .
shift so that complete cycle of rotation is completed every 28 days.
-__.-..m. _ . . , . _ . , _ _ . .
(, ;
. (_,
- 12. Question 8(cl: What will be required to return facility to operational readiness? The modifications required to return the facility to operation have not yet been detennined. The PG&E economic analysis filed on December 31,1980' described a range of modifications identified by a Bechtel Corporation study as potential backfit requirements. In addition to modification it is likely that most existing equipment would be overhauled and preoperational
; performance tested before startup, and the plant would perform i startup tests similar to a new plant.
- 13. Question 8(d):
Is there known deterioration of any components such that replacement is ce6templated in order.to retain adequate standby conditions - in order to achieve operational readiness? Systems that are not needed in the cold shutdown mode are not being maintained, and consequently should be overhauled and tested as
, above prior to operation. However, there is no known deterioration i .of any components such that replacanent is contemplated in order to retain adequate' standby conditions, or opera'tional readiness.
l 14. Question 8(e): t Has state of technology advance to such an extent that any signifi-cant. components on instrumentation and control systems will need to - l, be modified to achieve operational readiness?. i The licensee has informed the staff that it is not aware.of any instrumentation and control systems which would require modifica-ll5 tion due to technological obsolescence, but may elect to do some 'q ( modification because of the present day availability of improved I 4 e 6
+* e w + < s - o d. . e..
- k. )
. 1.
ins tru.aenta tion. Some changes would be made as part of seismic upgrading which has already been started. The review of the acceptability of Humboldt Bay Unit 3 instrumentation with rispect to both seismic qualification and current NRC requirements would be
~
considered by the staff prior to approving restart for the Humboldt Bay Power Plant, Unit No. 3. 5% c .. Vernon Rooney 1 Subs:ribed and sworn to before me this*it'- day of November, 1981.
! "i n C( ..;::.
Notary P,ublic My commission expires: a :. t , e ', 5 ;.- 6 9 0 e
*+
e k
. i
(,
,,' ) -
VERNON L. ROONEY, JR. PROFESSIONAL QUALIFICATIONS I am a Senior Project Manager in the Division of Licensing, Office of Nuclear Reactor Regulation of the U. S. Nuclear Regulatory Conmission. In~this position my responsibilities include nanagement and, coordination of matters related to license changes for operating reactors, and interacting with the licensee and the Office of Inspection and Enforcement in matters related to the safety of the plant. I have been assigned as a Project Panager for operating reactors since I joined the U. S. Nuclear Regulatory Commission in October of 1972 except for a period of about a year in 1978 when I was assigned to the Reactor Safety Branch and perforred technical reviews of operating reactor license amendment applications in the areas of core physics and thermal hydraulics. I received a B.S. degree with a' major in chemical engineering .from Leland Stanford, Jr. University in 1951. I received an M.S. decree in 1969 and a Ph.D. degree in 1970 from the University of Arizona with a major in nuclear engineering and a minor in physics. From 1951 to 1961 I was employeed by General Electric Company at Richland, Washington and was involved primarily in operation of various Hanford pro-duction reactors and the Plutonium Recycle Test Reactor. In addition to reactor operating experience, th's period also in'cluded experience in reactor production scheduling,' new reactor startup and testing, and major reactor modi'fications. From 1961 to 1972 I was employed by the Atomics International Division of North American Aviation. I supervised the installation and operation of the e SNAP 8 Experimental Reactor. This included direct management of the operating and maintenance personnel from initial startup through final shutdown and dis-assembly of the plant. I was lead Engineer for the postmortem analysis of the SNAP 8 Development Reactor and performed systecs analysis and test planning for the Closed Loop Systems for the Fast Flux Test Facility. I am a member of the American Nuclear Society Physics and Operations Divisions.. e e e e e 6 , e +
. . ~. -, ~.
(r i
. ATTACIGENT 1 UNITED STATES OF AMERICA ~
~
NUCLEAR REGULATORY COMMISS10h BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PACIFIC GAS AND ELECTRIC COMPANY Docket No. 50-133 HUMBOLDT BAY POWER PLANT ) (Amendment to facility ooerating UNIT NO. 3 ) license)
, AFFfDAVIT OF TOLBERT YOUNG JR.
I STATE OF CALIFORNIA ) COUNTY OF CONTRA COSTA ) SS I, Tolbert Young Jr., being ddly sworn do depose and state as follows:
- 1. I am employed by the U.S. Nuclear Regulatory Commission in the
. Office of Inspection and Enforcement, Region V, Walnut Creek, California. My professional qualifications are attached.
- 2. I am Chief, Reactor Projects Section 2 of the Reactor Operations
. Project Branch, and have responsibility to direct the regional inspection program in the area of reactor operations at nuclear i power plants, research and test reactors. I.am the direct supervisor of reactor operations inspectors who have inspected the Humboldt Bay Power Plant.
- 3. I. have read the Atomic Safety and Licensing Board's Memorandum and Order, dated October 21, 1981, regarding "Humboldt Bay Power Plant Unit No. 3 - Amendment to Facility Operating License".
- Regarding Board Questions Number 2 ("Are applicable regulatory requirements currently being met by licensee?") it is my i professional opinion, based on the inspections performed at the
,i
- facility and with the exceptions of identified items of noncompliance
. or exemptions granted by NRC-NRR, that the licensee is currently c' meeting applicable regulatory requirements. The exemptions that .
l
. I. am aware of are described in Mr. Vernon Rooney's testimony,to be filed . November 91,1981. *
(1 -
'l (
i) 1 I
+ u-
. . - f%V W-U * '-*4~ e ** am o w, q esene em , , p.e,an w . , .., , ,,.... m , , ... , . , , ,,, , , , ,
. 1
, . (' )
2
- 4. I have read the Declarations of Vernon Rooney, submitted in these proceedings and concur with the opinions and conclusions sta.ted in each of the declarations.
I attest that the foregoing affidavit is true and correct to the best of my knowledge and belief. k i wblbr) Wi-?YYY~Y, T61bert . Young Jr.' # Subscribed and sworn to before me this /) ' day of Mn + A-- , 1981 - s i / i c: n:nnmunmunenen.unnumuunuuus
. O F FICI A L S F. A L !
> s - /n..T .' -b. J ; j l 4 . f _ [ f'.f,l.'*\ JANET 5. ANDEi:5ON !
c^'***" No.tary Public ' ' i
~
b e i- '
"*'*"e com n*s*cus*ta coun te '^
l/ y My comm. Espues Dec. 7.1984 v cua:nman.mumunumumumumnum ' My Comision expires: 9 7-d V b e t e 7 . ~ 1
~
I
- g 4
i e, e ete e t hg w .a sm e q w g. .e e a= &Suboe esem e ow,,,_.g.. 4 ega,.- e,.
('
)
Tolb,ert Young, Jr.
~
Professional Qualifications Region V - Walnut Creek, California Office of Inspect 6n and Enforcement . My name is Tolbert Young, Jr. I am a Reactor Inspector with the Office of Inspection and Enforcement, assigned to the Walnut Creek, California Regional office. I have a Master of Science Degree in Teaching in Mathematics. I received ' a B.A. in Mathematics and Physical Sciences from George Washington University l in 1966 and my Masters from American University in 1968 - both schools are located in Washington, D.C. I have a Professional Engineer certification in Nuclear Engineering from the State of California. I served 20 years in the U.S. Army, retiring in 1971. In 1961. I attended the U.S. A.rmy Nuclear Power Plant Operators' Course. For the next ten years, I served in different capacities throughout the Army's Nuclear Power' Program, qualifying as Equipment Operator, Control
- Room Operator, Shift Supervisor and Plant Superintendent. In 1966. I was appointed to the Training Division of that program and served in progressively more responsible positions until 1969 when I was appointed as Chief Instructor of that Division. In my capacity as Chief Instructor, I was responsible for the training of students and operators in all phases of nuclear power plant operations and maintenance.
In June 1971. I joined the then Atomic Energy Comission as a Reactor Inspector in the Region I, Newark, New Jersey Office. Since that time, I have been the principal inspector for over 15 research, test and power reactor facilities. From August 1972 to March 1974, I was assigned as principal inspector for the Vermont Yankee, Pilgrim 1 and Millstone 1 . facilities, all Boiling Water Reactors (BWR). In June 1974, I was assigned as principal inspector for Diablo Canyon and was appointed resident inspector there in August 1978. In March 1981, I was reassigned to the regional office and became the principal inspector for San Onofre 2 and 3. In August 1981 I was promoted to my present position as Chief, Reactor Projects Section 2, Reactor Operations Project Branch. I have received the following special training: .
- 1. Fundamentals of BWR Plant Operations 1972
, : 2. BWR Technology '
1973
- 3. Pressurized Water Power (PWR) Reactor Facilities 19.74 !
- 4. PWR Refresher Training 1975 .
1976
! 5. PWR Simulator *Traiping
- 6. BWR Facilities . 1976
, i '
4
** ** * ** em me =% . =q ene m - + = , . ..e ee .me . ee = , ,e+.- ,. . . - * * = = -
. i *
)
ATTACHMENT 2 f- ' RESubT5' 0F ]NSPECTION EFFORTS IN 1980 AND 1931 AT HUN . (DN 50-133) , Inspection of Inspection
- Fung:tional Area Dates 14anhours Rep,o,r,t Nos. Resul ts
' Operational 5/20-22/80 34 50-133/80-02 Clear: ; g 3. .. ; .
i 10/25-24/81 23 50-133/81-05 Clear . Sa fcpard s. 11/19-Pl/79 18 50-133/79-03 Clear 1%/15-18/80 32 50-133/P.0-05 Clear 4/.06-09/81 . 27 50-133/81-02 Clear ,
.$!stirrials 5. .. .
- Accoun ability. '24 50-133/81-01 .. Clear . . - . ? h .h.L .! :
5/08;09/8). ch'; ;l '. - - 8.-
; V.'- "~; ' ' *
~'
r
, , l . ---
. r .- .
'~*# -
- i{calth 3/24-28/80 ;'- 38 Infraction - Failure',-
50-133/80-0)
Physics 1 i-ss-
' 1. - .:.
a
- to post high'Yadiation area. . :' .' - .
* 'S 4. - r.' -
Infraction - Failure to
- . i.. .p , .. : . .
.,G ..-
control access"to hi
- ' c ; c y.; .: .y i 't" .: . -;.%,.
g,- ,. . radiation area.'.p',:'gh -
~ L .'
. '; ' - . /- Deficiency - Failure to ir :s };.h. -
- 1abei container. Q.
' h- - 12/01-05/80.-? 60 -
- SD-133/80-04 Infraction - Failure to complete shipping papers.
8/29 - 7/2/81 34 50-133/81-03 Viol,ation - Severity .
. Level V - Liquid waste system vent men.itor set to alarm at 100 mr/hr instead of 10 mr/hr.
Special: 11/10/80 5 50-133/80-03 Clear To . Examine
' Effects cf Eart h.1uake
- Other: -
Indeper. dent '10/17-22/81* 38 50-133/81-04 Clear Inspection: . l;ecsurement Verif.ication-(* Announced inspection - all others were unannounced.) ~ i i . . I e ., e -
- t D-
T , . ( , ; UNITED STATES OF A!! ERICA NUCLEAR REGULATORY COMl11SSION
, BEFORE THE ATOMIC SAFETY AND LICEftSING BOARD .
In the flatter of-PACIFIC GAS AND ELECTRIC C0!!PANY
) Docket No. 50-133 OLA (Humboldt Bay Power Plant, Unit No. 3 )
4-Amendment to Facility Operating License) AFFIDAVIT OF INA B. ALTERMAN AND
,; JEFFREY K. kit 1 BALL ON SEISMIC EFFECTS AT HUMBOLDT BAY .
I, Ina B. Alternan being duly sworn, state as follows: l 1. I am employed by the U.S. Nuclear Regulatory Commission as a -
' Geologist in the Geosciences Branch of the Division of Engineering. Office ofifuclearReactorRegulation. A copy of g professional qualifications are attached and are true and correct to the best of g knowledge and belief.
. I, Jeffrey Kimoall, being duly sworn, state as follows: I am emplopd as a Seismologist / Geophysicist in the Geosciences Branch of the Division of Engineering Office of Nuclear Reactor Regulation. A copy
. of my professional qualifications are attached and are true and correct to the best of y knowledge and belief.
- 2. Question 4 in the Li' censing Board's Memorandum and Order of
^
October 20, 1981 stated: . Has there been any evidence whatsoever of seismic effects within the exclusion area? If so, please describe. , The Staff's reply to this question is provided below. . G ' k
3 3.' Since the licensing of the Huabol'dt Bay Nuclear Power Plant in i 1962, two significant moderate seismic events have occurred in the site locality: one on June 7,1975, and the other on November 8,1980, after
! .the plant had been shut down by the NRC pending resolution of some faulting problems. The first of these, in 1975, had its epicenter 35 km south of
- Eureka, with an ML =5.2, and caused significant damage in the region. There were no geological or surficial effects of the earthquake within the exclusion area. The only known effects nearby were in the King Salmon Trailer Park, a l half-mile west of the plant, where blacktop cracks occurred, and on a roadway i one mile south of the plant in Fields Landing, where similar cracks were observed.
't
- 4. Aft'er the 1980 earthquake, which had an epicenter.at least 60 km west of the California Coast on the sea floor, and an M =7,g a team of NRC staff engineers and a geologist visited the site to examine the effects of f
the earthquake on the plant, the site, and the region. A report on the effects of the earthquake on plant structures was issued on January 19, 1981 and later published in April 1981 as NUREG-0766 (" Effects of November 8, 1980 Earthquake on Humboldt Bay Power Plant and Eureka California Area"). l 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 f , the earthquake on Humboldt Bay Unit 3 were minimal and did not endanger the health and safety of the public. The 1975 earthquake had more energy associated with the higher frequencies than did the 1980 earthquake. In t general the 1975 event was of shorter duration compared to the far-field
, tlongerdurationnatureofthe1980 earthquake,qualitativelyindicating los damage potential. -i .
i
- L' ;
. 5. Accompanied by our consultant, Tim Haitt of the USGS, Ina Alterman toured the plant site and region. No ruptures, or land slumps or slides of the ground surface were found within the exclusion area of the plant. No evidence of surface effects of any kind were seen in the exclusion area or on the marine terrace, on which the plant is built, just outside the exclusion area. The surface effects closest to the plant were seen in King Salmon, again in the trailer park. There, new blacktop was freshly cracked, one crack going through a concrete drainage box set into the roadway. This location is near the projected surface trace of the Bay Entrance fault.
While the cracks do not suggest motion along the fault, it is interesting to observe that, further away, a number of cracks in the blacktop that suggested liquefaction were seen near a seafood stand on a road in Fields
, Landing that is also along the trace of the Bay Entrance fault. This was
. the same location as the Fields Landing crack observed after the 1975 earthquake.
- 6. An open-file report by the U.S. Geological Survey (Lajoie and Keefer)E reports that the asphalt at one of the abutments of the highway bridge near the entrance to the plant was broken by two fresh cracks, a l few millimeters wide, which the authors attributed to slight displacement
- of the bridge during the earthquake. '
l l _1] Lajoie, Kenneth and Keefer. David. " Investigations of the 8 November i i 1980 earthquake in Humboldt County, California," (1981), USGS Open File Report 81-397. l .. t
(
, 4-The projected trace of the Buhne Point fault, discovered recently by PG&E consultants' Suminary Report of October 1,1980,2/ comes close to this bridge, but the USGS reported that no evidence was observed to suggest fault rupture as the cause of the cracks.
- 7. The severest effects of the event within the plant region were
[ in Fields Landing, where an MM VII is interpreted.M Here houses were 1 knocked off simple foundations, glass shattered, and sone chimneys fell or were partially damaged. -Besides a few fresh cracks in the roadtop previously mentioned and sorite fresh cracks in the sand quarry, no other
! geologic effects of the earthquake were observed. About 40 miles north of the plant, liquefaction-induced phenomena were observed on Big Lagoon e
Spit due east of the epicenter. These included sand boils, surface cracks
- 1ateral spreads, and slumps at shoreline, in unconsolidated medi.um to coars>r sand. Descriptions of other localities'with minor surface disturbance resulting from the 1980 earthquake may be found in the USGS open-file report.
i _2/ Woodward-Clyde Consultants, " Evaluation of the Potential for
, Resolving the Geologic and Seismic Issues of the Humboldt Bay Power
. Plant Unit No. 3 Sucinary Report and Appendices," (prepared for
! Pacific Gas and Electric Company, Oct.1,1980).
t l 3/ Ruth B. Simon, " Intensity Survey for 8 November 1980 Eureka, Cal.ifornia earthquake," Seismological Society of America (Abstract). SSA meeting, March 1981. i l .
- f. .
e
~
l .
}
O
. 5-
~
- 8. PG&E's geological and seismological consultants, Woodward- -
Clyde Consultants, Inc. submitted a report in October,1980, referred to heretofore, describing the results of their geologic and seismic studies
, of the plant site and region with special emphasis on the locations, regional relationships and ages of last movements of the faults.
- U
.L.s t .
b ___. .- Ina B. Atterman 1 _ e., _ ye'ffffy tiniball Subscribed and sworn to before me this ///*/ day of November,1981 Y$ uf, ~A1 ERn Notary Public j Hy conmission expires:1L / es&& -
/ 0 e
t j e
*e 4
1 -
. .. . , . . . . , . , , _ . . . _ . . . . . . ~ , . . . . - . . . . - -
. t )
INA B. ALTERMAN, PH.D. GEOSCIENCES BRANCH OIVISION OF ENGINEERING U. S. NUCLEAR REGULATORY COMMISSION My name is Ina B. Alterman.and I am presently employed as a Geologist in the Geosciences Bran 5, Division of Engineering, Office of Nuclear Reactor
- Regulation, Washington, D.C. 20555.
. PROFESSIONAL QUALIFICATIONS I have a B.S. in Geology (1963) which was awarded Magna Cum Laude from City College of New York, where I was also a member of. Phi Beta. Kappa. My Ph.D. in Structural Geology was awarded in 1972 by Columbia University where I held a Faculty Fellowship.
~
My professional experience began with University teaching and field and laboratory research. I taught Introductory Geology, Historical Geology,
, and Optical Mineralogy in various colleges (City, Hunter, Barnard and Columbia) as a part-time lecturer while in Graduate School. As a full time Assistant Professor at Lehman College, starting in 1971, I also taught Structural Geology, Tectonics, and Igneous and Metamorphic Petrology until coming to NRC in October,
< 1979.
My major research activities were grant-funded field mapping, structural analyses of multiple deformation, mechanisms of ductile deformation, and ancient plate tectonics Some of this mapping, in Pennsylvania, is now included on the latest official eologic map of Pennsylvania, published by the Pennsylvania Geological Survey. or two sumers in 1976 and 1977, I did a study of linear' structures and brittle fracturing of the earth's crust for the National Aeronautics and Space Administration using Landsat and other remote sensing techniques. I am often sent papers on various aspects of structural geology to edit and/or
'; reviewforjournalsandproceedingsvolumes(forexample,JournalofGeology, BasementTectonicsVol.). My own publications include articles in the Earth Science Encyclopedia, Petrology Volume (still in press), articles on stratigraphy, mechanisms of slatycleavage formation, Paleozoic plate tectonics in the Appalachian Piedmont and late brittle faulting in the Appalachians.
E j At NRC I have been involved in thereview of recent geologic features near . Rancho Seco, and at the Washington Nuclear Plant No. 2 on the. Columbia River Basalt ' ' Plateau in Central Washington State. I recently supervised the compilation of l information concerning the geologic and tectonic setting for every nuclear facility
, in Califor.nia, including university and industrial research reactors and power plants.
I am a member of -he following professional and scientific organizations: l
- 4 ! Geological Society of America -
4 American Ge'ophysical Union .
. American Association for the Advancement of Science i s New York Academy of Science i Potomac Geophysical Society -
i Washington Geological Society
; Sigma XI i Phi Beta Kappa
. e e aw w # 9 as we **wa sa e sey +~. sow.* *e =='69* ** *e ** *e. e -o e e , e e *
'e .
. (' -
)
JEFFREY K. XIMBALL' - GEOSCIEtiCES BRANCH, '-314 . - / DIVISION OF EliGIriEERItiG U. S. NUCLEAR REAGULATORY COMISSION ' WASHINGTON, D..C' 20555 . 1 Hy.na:e.is Jeffrey K. Kimball. I am employed as 'a Seismologist / Geophysicist reviewer, Geosciences Branch, Division of Engineering, Office of Nuclear Reac' tor Regulation. I received a B.S. degree in Oceanography from the. University of Michigan in 1977 and a M.S. degree in Geology from the University of Michigan in 1979, 7 .. with a specialty in seismology and geophysics. 1 I'bave been employed by NRC since May 1980 as a Seismologist / Geophysicist l
. reviewer as applied to the evaluation of applications for construction - and operation of nuclear facilities, and to determine the thoroughness..of this information for defining the seismic hazard for which facilities must be designed. Since joining the Nuclear Regulatory Commission staff,'I have a participated in the licensing activity for approximately ten sites. _
From 1977 to 1980, I was a research assistant and teaching issistant at'the University of Michigan. My activity as a research assistant included seismic data compilation studies for the U. S. Geological Survey and data analysis and operation of a nine station seismic network. My M.S. thesis work involved a study on surface wave dispersion of the Atlantic Ocean Basins and has been presented at national meetings of professional societies and published ih a professiona-1 journal. Teaching assistant experience consisted of helping teach both introductory and advanced geology field courses.in
!!yoming for two summers and an introductory geology laboratory class at the
~
~
University of Michigan. . I am a member of the American Geophysical Union and the Seismological Society I of Ararica, and have co-authored 7 publications ' including abstracts of pre- ' sentations to professional societies and NUREG documents. f aj . g
.L.
y; [. . ] ' j . t D
.....~,-
,e ,,-v---, -
- - - - - - - - - - - - , - , - - - , , _ _ _ _ , _ ,- - - e-- , - , , --,- ___A
. ;) . a. ) ,
4 ' I 7590-01 UNITED STATES NUCLEAR REGULATORY COMMISSION DOCKET NO. 50-133 PACIFIC GAS & ELECTRIC COMPANY , HUMBOLDT BAY POWER PLANT ISSUANCt ur uixtLiux's utLidiun UNDER . 10 CFR 2.206 Mr. Ron Guenther by letters dated January 16, 1982 and June 8, 1982 has petitioned for the decomissioning of Humboldt Bay Power Plant Unit No. 3. Mr. Guenther's letters have been treated as a request for action under 10 CFR 2.206 and have been referenced to the Office of Nuclear Reactor Regulation. Upon review of this matter, the Director of the Office of Nuclear Reactor Regulation has determined that the request does not provide an adequate basis for,, decommissioning of the Hutoldt Bay Power. Plant, Unit No. 3. Accordingly, the request has been denied. Copies of the Director's decision are availabie for inspection in 'the Commission's Public Document Room,1717 H Street, N.W., Washington, D.C. 20555 and at the Humboldt County Library, 636 F Street, Eureka, California 95501. A copy of the decision will also be filed with the Secretary for the Commission's review in accordance with 10'CFR 2.206(c) of the Commission's regulations, i As provided in 10 CFR 2.206(c), the decision will onstitute the final action r of the Commission twenty-five (25) days after the date of issuance, unless' the l Commission, on its own motion, institutes a review of the decision within that s time. j i W ~ i g Harold R. Denton, Directoi
'i Office of Nuclear .'eactore .
;usation t
i Dated at Bethesda, Maryland this 7th day of July 1982.
~
m t1
/0 j f 4 = mg $ e agAbbe e g eme t er
- em Op= pm e emp* &e&P & * 'O = 4 4
- . , , y- .. ,__ m, r - - - - - - - , - - .
- -. :a.N- . . = = ~- & . . . ==.=$ - l l-- ~ ~-
.. $ .. a
. (,1 '
/.//-f/4 9 UNITED STATES OF AMERICA NUCLEAR REGULATORY C0!'tiISSION
, ATOMIC SAFETY AND LICENSING BOARD 9 Administrative Judges: .
Robert M. Lazp, Chairman Gustave A. Linenberger
- . - David R. Schink ,
In the Matter of )1 Docket No. 50-133-OLA l PACIFIC GAS AND ELECTRIC COMPANY h) (Hunboldt Bay Power Plant October 20, 1981 Unit No. 3 - Amendment to Facility Operating License)
))
)
l Y i l' MEMORANDUM AND ORDER
- .( . ,
in an order entered on July 14, 1981, the Atomic Safety and Licensin'g
~
Board (Bbard), directed Pacific Gas and Electric Company (Licensee) to submit .' a written statement setting forth its intentions regarding plant modifications I necessary to bring Humboldt Bay. Power Plant. Unit 3. into compliance with
- current NRC requirements and, if it wished to retain the operating authority -
pro'vided in Facility Operating Li, cense No. DPR ,7 , a proposed schedule for ~ completing such plant modifications. In response thereto.' on August 13, 1981 Licensee filed an affidavit executed by its Senior Vice President for 1 - I- Facilities Development. According to Licensee, additional studies are necessary to evaluate v'arious alternatives for the plant. These studies include updating Licensee's analysis of those actions which must be taken in order to resume (.. s power operation asfwell as various decomissioning options. Licensee has already embarked upon such a program which should be completed by December 15, 1981. d. j pksz-2. M O3 , % py
s _ n = ;. ~ ~ - - . = . - - = = . = . _ _ . _
. ()- -
4 ( : However, an additional six months will be required, to reassess the costs associated with various alternatives being evaluated, after the domission detemines backfit requirements for older plants such as Humboldt and f '~ l 1.ssues guidance on those requirements. I I, Licensee's response concludes with the statement that it is extremely reluctant to abandon a proven source of generation located in a relatively isolated area within its system and with the assertion that: 7."Since the unit. it its present cold shutdown condition. ' presents no risk to'.the health and safety of the public, PGandE believes that there is no compelling reason for this Board to issue an Order to Show Cause why the operating authority. for Humboldt Bay Unit No. 3 should be revoked. . We are convinced that it is beneficial to maintain the plant in an operational status pending a decision on NP.C backfit requirements and an assessment of their effect on the economics of returning the Unit to operation." j k Before taking further action in this proceeding, the Board would like , to have the views of the NRC Staff on Licensee's assertion that the Humboldt ! Bay nuclear plant in its present cold shutdown condition, presents no risk , t, ., l to the health and safety of the public. Specifically, the Staff is directed to provide answers to the following Board questions: ( . . I ,
- 1. 9 hat regulatory requirements apply to a plant in cold shutdown mode. ,
l I 2. Are applicable regulatory requirements currently being met by Licensee? l .. l 3. Has the Staff given consideration to the question of whether ! the exception' ally long shutdown of Humboldt Bay Unit No. 3 might give rise to the potential fpr significant safety l ! problems? What unusual problems might arise? l i 5
- 4. Has there been any evidence whatsoever of' seismic effects within l the exclusion area? If so, please describe.
[ t . .
i .a _ v ,s _ ,_ ~~ . . C' " ~ .. __
-. - ~
_j 3 . What ntly in force? to physical security(Assume procedurts? = What physical security measures are CYcurre
- 5. w and end of 19827 n was date and nature of last changeWhat what w6 changes
' no change in operational status). What ly perrunned byWhat !atttine non-surveillance? What surveillance is being routine m 6.- date and nature of last change f d end ed? in ofrou CY 19827What were the resu (Assume no change in chinges are planned between now anroutine sur i
. of surveillance efforts operational status) location ~and What is conditions ofpo
'7.
'What is status of facility,dincluding spent fuel? com ars routinely operated; ' fuel integrity and includingstorage and assure itslity ando
" currently being done to maintain i safety with respect to security i t nance , crit being ca perfomed toelate Describe physkeal anddpreventive duty cycle of ma n e crew?
4 standby
- 8. assure continued integrity of safety r facility to operational readines -
- ize, makeup (by discipline) an ,
What will be required to return d uate standby conditions -Has stat Is there known deterioration of any comis c diness? - in order to achieve operational rea y significant components onill nee
- advanced to such an extent that aninstrument
?
. achieve operational readiness ORDER l day of October 1981 #
F It is this 20th . ORDERED , date of service of this Order, the l That within thirty (30) days 'of thes to the Board's question! L NRC staff shall file written response ts regarding the questions or f the above. Other parties may file their cormnenithin fifteen (1 - the Staff's responses thereto w D, , Staff's responses. FOR THE ATOMIC SAFE 1
', =
Chaiman
; Robert M. Lazo, JUDGE Yi l '.! .
ADMINISTRATIVE - y ' bk ~~ .
% *-Nv
~
JJ: . - ~ _ . :_ _ _ ~v ,
~ -~ - ~ - -
a . ..
* . 488- f/--Y9
_ UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD 5 , Administrative Judges: - f Robert M. Lazo, Chairman ( 1 - Gustave A. Linenberger David R. Schink , i. i ~ --
),
In the Matter of 1 Docket No. 50-133-OLA
)
I
- . PACIFIC GAS AND. ELECTRIC COMPANY h 1 . - l (Humboldt Bay Power Plant- h October 20, 1981
' Unit No. 3 - Amendment tc Facility i Operdting License) ll
.3 . ,
d j > __ ) e M840RAN00M AND ORDER
! ~
In an order entered on July 14, 1981, the Atomic Safety and Licensing
~
Board (Bbard). direct.ed Pacific Gas and Electric Company (Licensee) to submit
a written statement setting forth its intentions regarding plant modifications necessary lo bring Humboldt Bay Power Plant. Unit 3, into compliance with current NRC requirements and, if it wished to retain the operating authority
- provided in Facility Operating Li, cense No. DPR-7, a proposed schedule for i
d, completing such plant modifications. In response thereto, on August 13,1981 Licensee filed an affidavit executed by its Senior Vice President for
'. Facilities Development.
i,
,7 According to Licensee, additional studies are necessary to evaluate 'I ~ . Various alternatives for ,the plant. These studies include updating l Licensee's anal.ysis of those actions which must be taken in order to resume r- .
power _ operation as well as various decomissioning options. Licensee has already embarked upon such a program which should be completed by December 15, 1981.
. 7 '
y~ s w 2 w -9 0 3 u 3 ep - _ _ - . . . .. _ _ - _ _.
. ~_ . _ a t . .
[.. L
't ,
However, an additional six months will be required, to reassess the costs 3
- l. associated with various alternatives being evaluated, after the Commission determines backfit requirements for older plants such as Humboldt and i . _ _ .
- issues guidance on those requirements.
}
Licensee's response concludes with the statement that it .is extremely reluctant to abandon a proven source of generation located in a relatively isolated area within its system and with the assertion that:
. '"Since the unit it its present cold shutdown condition. ~
presents no risk to.the health and safety of the public, PGandE believes that there is no compelling reason for this Board to issue an Order to Show Cause why the operating authority for Humboldt Bay Unit No. 3 should be revoked. - We are convinced that it is beneficial to maintain the p1' ant in an operational status pending a decision on NRC backfit requirements and an assessment of their effect on the economics of returning the Unit to operation." i Before taking further action in this proceeding, the Board would like to have the views of the NRC Staff on Licensee's assertion that the Humboldt Bay nuclear plant in its present cold shutdown condition, presents no risk to the health and safety cf the public. Specifically, the Staff is directed a to provide answers to the following Board questions:
- 1. shat regulatory requirements apply to a plant in cold' shutdown
, mode.
s
- 2. Are applicable regulatory requirements currently being met by Licensee?
- 3. HastheStaffgiv.enconsiderationtoIIhequestionofwhether the exception' ally long shutdown of Humboldt Bay Unit No. 3 might give rise to the potential fpr significant safety problems? What unusual problems might arise?
- 4. Has there been any evidence whatsoever of seismic effects within
- the exclusion area? If so, please describe.
t I a... . _ . ._ . ._ _ . . _ _ _
. < . . a
- lj _ :
,,-- - -3
$. 5. What physical security measures are currently in force? What was date and nature of last change to physical security procedures? What changes are planned between now and end of CY 19827 (Assume ~ no change in rational status).
- 6. What .J"- 1s being routinely perrun eed by 16Et What was date and nature of last change in routine surveillance? What "
changes are planned between now and end of CY 19827 What non-
. routine surveillance has been perfonned? What were the results of surveillance efforts in 1980, 19817 (Assume no change in l ; operational status)
- 7. What is status of facility, including components and systems that l c
'are routinely operated; and including location and condit. ions of -i storage of all new, partially used, and spent fuel? What is
- currently being done to maintain fuel integrity and assure its jj safety with respect to security, criticality and themal stability?
- 8. Describe physical and preventive maintenance being performed to assure continued integrity of safety related components. What is size, makeup (by discipline) and duty cycle of standby crew?
~
!~
- What will be required to return facility to operational readiness?
Is there known deterioration of any componente such that replacement . is contemplated in order to retain adequate standby conditions -
- i in order to achieve operational readiness? Has state of technology i advanced to such an extent that any significant components on instrumentation and control systems will need to be modified to *
. achieve. operational readiness?
i ORDER It is this 20th day of October 1981
' r l
- ORDERED . .
That wit!hin thirty (30) days 'of the date of service of this Order. the [ NRC staff shall file written responses to the Board's questions set forth i above. Other parties may file their connents regarding the questions or l the Staff's responses thereto within fifteen (15 days) after service of the Staff's responses. i . FOR THE ATOMIC SAFETY AND LICENSING BOARD =
) '
h w Robert M. Lazo, Chairman ADMINISTRATIVE JUDGE i - I d
. , - . . . - . . . . - . - . - - . _ - - - - . - _ - - . - - - - - - , . - - - - - - - - - - . - . . .--.-....,m.w--- . - - - ,,---,.*------r.---.--,-,-,---,v--t_ . , , , - - +. ..
, -[ UfdTED STATES b 3 :; .
,d. 3.
.a
- e. 14U01 E Ali REGUI.ATORY COMMISSION wasi.mc ros, o. c. aosss g g{
~
~
fY (, November 19, 1981 Richard H. Lazo, Esq'., Chairman Gustave A. Linenberger Administrative Judge Administrative Judge-Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, DC 20555 Washington, DC 20555 Dr. - David R. Schink Administrative Judge Department of Oceanography Texas A & M University College Station Texas 77840, , In the Matter of' PACIFIC GAS AND ELECTRIC COMPANY (Humboldt Bay Power Plant, Unit No. 3) . Docket No. 50-133
Dear A. Inistrative Judges:
In its Memorandum and Order of October 20, 1981, the Licensing Board i directed the Staff to provide answers to eight questions within thirty days of the date of service of the Order. Order at 2-3. This letter regarding question 1 and the accompa_nying affidavits of Vernon Rooney, Project Manager, Tolbert Young, Jr., 0'ffice of Inspection and Enforcement, and Ina Alterman and Jeffrey K. Kimball, Geosciences Branch, variously addressing the balance of the questions constitute the Staff response. Question 1: *What regulatory requirements apply to a plant in cold, shutdown mode?" The regulations 'with few exceptions.M do not contain express refer-ences which indicate their applicability to a plant in cold shutdown. Generally, Part 50 contains the requirements for normal operation and _ certain transient conditions. In the absence of any express exclusion JJ Appendix R focuses on the protection of structures, systems and components associated not only with achieving safe shutdown but also maintaining safe shutdown from the probability and effects of fires.* The tem " safe shutdown" as used in Appendix R to 10 C.F.R. Part 50 applies to both hot and cold shutdown. Appendix R(I). In addition,
~
section 50.54(q), for example, requires a licensee " authorized to possess and/or operate a nuclear power reactor" to have emergency plans which meet the standards in i 50.47(b) and the req'irements u ( in Appendix E to Part 50. g .
o
-a . '* T .
- z. .
in the regulations of cold shutdown and because it is one of the five modes of operation defined by the NRC and in a facility's license, the ' regulations that apply to a plant in normal operation will also apply to a plant in cold shutdown. Therefore, the provisions of 10 C.F.R. Parts 20, 30, 40, 50, 51, 55, 70, and 73, which are not expressly limited by their tenns, are applicable to plants in a cold shutdown operating mode. . However, with respect to a facility whose license is to be limited to ' shutdown condition, the various provisions applicable to normal operation, transients and accidents should be construed as relating to - the' shutdown condition (i.e., normal shutdown conditions, transients affecting the shutdown condition, accidents and abnormal occurences as they affect the shutdown condition). For example, those provisions requiring consideration of LOCA conditions would then consider the effect of loss of coolant under conditions of a cold depressurized primary system and a core with essentially no decay heat. Thus, in many cases very little , if anything.. i.s needed to demonstrate compliance. - For example, little would be needed to show ap against pipe whip (General Design Criterionwhen 4)propriate all fluidsprotection are cold and depressurized. Rooney Affidavit. The licensee must also comply with any conditions or requirements , imposed by Order, its license and technical specifications. Humboldt
- Bay has not received Orders regarding the implenentation of NUREG-0578
. and NUREG-0737 standards and modifications. -
Sincerely, (..C f LA Steven C. Goldberg Counsel for NRC Staff - cc: w/ enclosure Service List. e e 4 1 e o e a e e
- - - - . - , -, ---.-.,---,-..w.. - ----------er,.--,w--,--,-- --,-.-~w- - - - , . - - ----w----w-----,.m,--e,-er7 ---~------,-----,e ----
UNITED STATES OF A!1 ERICA
; NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
))
PACIFIC GAS AND ELECTRIC COMPANY ll Docket No. 50-133
)
(Humboldt Bay Power Plant, ll Unit No. 3) ) AFFIDAVIT OF VERNON ROONEY RESPONDING TO MEMORANDUM AND ORDER OF OCTOBER 20, 1981 I, Vernon Rooney, being duly sworn s. tate the following: ,
- 1. I am employed by the U.S. Nuclear Regulatory Commission as a Senior Project Manager in the Division of Licensing Office of Nuclear -
Reactor Regulation. A copy of my professional qualifications are attached and are 'true and correct to the best of my knowledge and belief.
- 2. I am the project manager assigned to the Humboldt Bay facility.
- 3. In its Memorandum and Order of October 20, 1981, the Board directed the Staff to answer questions listed on pages 2-3. The Staff's response to questions 2, 3, 5-8 are provided below and in the attached affidavit from the Office of I'nspection and Enforcement.
l .
- 4. Question 2:
Are the applicable regulatory requirements currently being met by . Licensee?- . W.ith respect. to a facility whose license is to be limited to shutdown condition, the various provisions applicable to normal operation, ( ggg3s363 Po(T .
. r transients and accidents should be construed as relating to the shutdown i condition (i.e., normal shutdown conditions, transients affecting the shutdown condition, accidents and abnomal occurences as they affect the , shutdown condition). For example, those provisions requiring considera-tion of LOCA conditions would then consider the affect of loss of coolant under conditions of a cold depressurized primary system and a core with essentially no decay heat. Thus, in many cases very little, if anything, is needed to demonstrate compli.ance. For example, litt1,e would be neaded , to show appropriate protection against pipe whip (General Design Cri ' terion 4) when all fluids are cold and depressurized. Based on review of correspondence with the licensee and the results of , surveillance conducted by the Office of Inspection and Enforcement (See ( attachment 1), the' staff is aware that applicable regulatory requirements are not being met in the following areas:O (1) 10 C.F.R. 150.46 and Appendix K (ECCS). 10 CFR 550.46(a)(1) states that ECCS cooling performance shal1 be calculated in acc'ordance with an acceptab1'e evaluation model. Appendix K sets forth required model features. The licensee has not performed ECCS analyses for Humboldt Bay using currently approved ECCS models and, therefore, is , not technically in compliance with the noted regulatory requirement. J/ Exemptions have been granted by the Staff under 10 CFR i 50.12 f.or the following. An exemption to the containment integrated leak , rate test requirements of 10 CFR Part 50, Appendix J, III(A) was . granted on July 13, 1979. An exemption to the requirements for operator training in 10 CFR Part 55 Appendix A, 53a to include ten reactivity control manipulations every two years was granted on January 11, 1978. An exemption to the requirements of 10 CFR 573.55 relative to implementation dates was granted on March 16, 1978. ( 9 o
- h. . .
ii i
4 However, despite the. absence of required calculations, emergency ( cooling is not required to remove fuel decay heat. Staff studies show that Humboldt Bay fuel has decayed sufficiently that air cooling is adequate to preserve cladding integrity. Therefore,
. measures to assure core cooling or mitigate loss of coolant consequences are unneccessary.
(2) 10 C.F.R. 650.48 and Appendix R (Fire protection). Section50.48(a) , requires a fire protection prograin that satisfies Criterion 3 of Appendix A to 10 C.F.R. Part 50. Section 50.48(b) states that Appendix R establishes fire protection features required to satisfy Criterion 3. Appendix R requires a fire hazards analysis and , certain fire prevention features. These have not been provided for ( Humboldt Bay. Nevertheless, the reactor is fully shutdown, with measures to assure continued shutdown as discussed in paragraphs 8 and 9 below. The mechanisms which maintain rod insertion would continue to function in event of fire. Protection of equipment.to assure the capability to shutdown is unnecessary. Fire protection for core cooling systems is not needed'because air cooling is adequate. Due to the long period since. shutdown, mobile ' radio-activity has decayed very significantly. The Staff, therefore, believes that in all cases the public health and safety is being protected, despite the fact that the lic'nsee e has not complied with , Appendix R' to 10 C.F.R. Part 50. k
- + _ - - , , . . - . - . - - . .- . . _ - - . - - , - , , , , - - . , , . ,.- , - - . , , . , . , - . .
- + .
_ 4_ (3) 10 C.F.R. Part 50 Appendix A Criteria 2 and 3. Criterion 2 i' requires design to withstand the effects of earthquakes. The Humboldt Bay plant does not meet this criterion. The Staff has considered the seismic capability of equipment important to safety. in the present shutdown condition of the plant and found it adequate ' to assure the continued protection of the public health and safety. Criterion 3 requires fire protection design, which is not provided at Humboldt Bay, as discussed above. . .
- 5. Question 3:
Has the Staff given consideration to the question of whether the exceptionally long shutdown of Humboldt Bay Unit No. 3 might give rise to the potential for significant safety problems? What unusual
- problems might arise?
Yes, the Staff has given consideration the this question. See answers to questions 5, 6, 7, and 8 for potential problem areas. The staff concluded that in all cases the public health safety is adequately protected. .
- 6. Question 5(a):
What phy'sical security measures are currently in force? Based on the requirements of 10 CFR 50.34('c) and 10 CFR Part 73 - (1976) and guidance provided in AEC Regulatory Guide 1.17 - 1973,
" Protection of Nuclear Plants Against Industrial Sabotage" and ANSI N18.17 - 1973, " Industrial Security for Nuclear Power Plants", the .
licensee' submitted the " Pacific Gas and Electric Company Humboldt t Bay Power Plant Security Plan" Revision 0 dated March 12, 1974
'(
- e S.
e
- - - - , ------ - - - - - - - n. , e - - ,--,--y--- - - - , , -,-ww
~'
v. O
. s.
~
Revision 1 dated April 14, 1975 and Revision 2 dated November 16, i 1976. Briefly, the current security program contains:
- 1) Designation of three areas within the owner controlled area at which access to the plant is controlled (Restricted Area, ProtectedAreaandInnerSecurityArea).
2') Surveillance and intrusion detection capabilities through the use of guard patrols, closed-circuit, television and intrusion detection systems. .
- 3) Personnel access controls ranging from vehicle access control at the Restricted Area to searches for weapons, explosives, ,
etc., and badging of personnel at the Protected Area.
- 4) Redundant communication capabilities to local law enforcement
( agencies to assure assistance can be summoned should the need arise.
- 5) Personnel selection, screening and appraisal programs .to detect aberrant behavior or other characteristics which could be a detriment to plant security.
- 6) Periodic training programs for plant employees to make them aware of their roles in plant security and the security procedures they are required to meet.
- 7) Periodic contract security force tr41ning program to provide ,
specia'lized training and requalification of all guards in the physical security program and procedures at the site. 4 6 e
. r '
Question 5(b): What was the date and nature of the last change to the physical security procedures? The most recent change was Revision 2 of the " Pacific Gas'and - ; Electric Company Humboldt Bay Power Plant Security Plan" dated November 16, 1976. This revision was submitted to clarify and consolidate information regarding implementation of physical security measures indentified in the licensee's letters of July 22, 1975 and August 6, 1975. ' . Question 5(c): What changes are planned between now and the end of CY 19827 (Assume no change in operational status) Based on an exemption from the requirements of 10 C.F.R. I 73.55 q issued by letter dated March 16, 1978 to Pacific Gas and Electric Company from the Staff, we do not anticipate any regulatory required changes to the Humboldt Bay security plan between now and the end, of CY 1982.
- 7. Question 6: -
What surveillance is being routinely performed by I&E7 What was date and nature of last change in routine' surveillance? What . '. changes are planned between now and end of CY 19827 What non-routine surveillance has been performed? What were the results of surveillance efforts in 1980, 19817 (Assume no change in operational status) , , Thestandardinspection(surveillance)programforashutdown
- reactor'is being performed at the Humboldt Bay Nuclear Power Plant.
l 5 This inspection consists of inspections of design changes and ( I .
~
modifications, activity of the Onsite Review ' Committee,QA program, L overall training program, fire prevention and protection, sur-veillance of equipment during extended shutdown, security and mat'erial accountability, radiation protection program,
. transportation of radioactive materials, and radioactive waste management.
These activities are inspected annually except when demonstrated satisfactory performance justifies reducing the frequency to once per 18 months. In addition, licensee event reports, instances of noncompliance, and various other areas identified by other NRC offices are inspected as required. Twenty percent of the inspector's time is used to inspect areas of his own , choosing., [ The last cha.nge in routine inspection occurred when the reactor was shutdown on July 2,1976, at which time operational aspects of inspection were scheduled at a reduced frequency consistent with the operational status of the facility and allocation of the' NRC's resources, resulting in the program described above. There have' been no other changes in inspecticn except for implementation of the Revised Inspectior. Program (NUREG-0397). and the general Opgrading and refinement of existing programs. No changes in the inspection program between now and the end of CY 1982 are anticipated. One nonroutine inspection was performed (pos't-earthquake inspection); , none are planned. Inspection efforts in 1980.and 1981 revealed
- three infractions, one deficiency and one violation-severity level V.
See Attachment 2. k e 4
----,,--.-m
. r
- 8. Question 7(a): .
i What is status of facility, including conponents and systems that are routinely operated; and including location and conditions of storage of all new, partially used, and spent fuel? . Humboldt Bay Power Plant, Unit No. 3 is in the cold shutdown condi.-
. tion. The master reactor switch is locked in the COLD SHUT 00WN mode which removes electric power from the control rods, all of which are fully inserted. W'ithout electric power the rods cannot be withdrawn. The key to the master reactor switch is in th,e locked key cabinet, and.the key to the key cabinet is in the possession of the Shift Foreman.. Components and systems that are routinely operated include the reactor cleanup system, the emergency boration system, the liquid radioactive waste processing systems, the ,
refueling building ventilation system (including the gas treatment ( system), nuclear instrumentation as required by the license, and the radiation monitoring system. The core is fully loaded with 140 partially irradiated assemblies and 44 new assemblies stored unde,r water. The spent fuel pool contains 250 spent fuel assemblies stored under water. Thirteen new fuel pins, but no assemblies, are stored in air in the new fuel storage vault. The reactor vessel head is in place and the shield plug is. installed.
- 9. Question 7(b):
What is currently being done to maintain' fuel integrity and assure its safety with respect to security, criticality and thermal
- stability?
- The safety of the fuel is maintained by the following measures: '(
M e
~
.g.
a) with respect to security, the licensee is in compliance with ( - - its 197C Security Plan and is audited against this plan (see answer to Question 5).
~
b) With respect to criticality, the rods are fully inserted with the master reactor switch locked in the COLD SHUTDOWN mode (asdiscussedabove). In addition, control, rod power is deenergized at various other locations. The liquid poison system is available f r backup criticality control of the reactor core if needed. Criticality in the spent fuel pool is avoided by the design of the spent fuel storage racks and the absence of large amounts of highly enriched fuel. c) With respect to thermal stability, the irradiated Humboldt Bay , fuel is maintained water covered. The staff has concluded that ( the fuel cladding would remain intact with only air cooling, if there were complete loss of water.
- 10. Question 8(a): .
Describe p'hysical and preventive maintenance being performed to assure continued integrity of safety related components. Physical and preventive maintenance is performed as necessary to
. maintain as operable the systems described in the answer to question 7. Technical Specification requirements for surveillance testing during cold shutdown include requirements for the fire protection, system, the gas treatment system, the ventilation system, '.
the radiation monitoring system, and the security systems.
$ i G
. r
- 11. Question 8(b):
(. What is size, makeup (by discipline) and duty cycle of standby crew? The Huinboldt Bay Power Plant, Unit 3 is at a site which also acconmodates two additional . fossil units (Units 1 and 2) in addition to two mobile emergency power generating units which are frequently used to provide peak load generating capacity in the absence of the shutdown Unit 3. The crew staffing the site operates all generating units, and is therefore not really a standby crew. The nonnal , minimum 7 man operating shift crew is maintained at all times. Each of the four shift crews have the following minimum personnel:
, Position Qualification Assignment' 1 Shift. Foreman Sr. Reactor Operator License entire plant
( 1 Control Operator Reactor Operators License Unit 3 only 1 Sr. Control Operator Reactor Operators License Units 1, 2 and 3 1 Control Operator No license Units 1 & 2 1 Auxiliary Operator No license Units 1 & 2 2 Auxiliary Operators No license entire plant The Senior Reactor Operator and Reactor.0perator Licenses have been maintained current with the exception of startup experience requirements (whicharenotpertinentforashutdowncondition).The shift crews rotate between day shift, swing shift, and graveyard , shift so that complete cycle of rotation is completed every 28 days. k ( . e
1, i
, 12. guestion8(c): What will be required to return facility to -(.
2 ' operational readiness? The modifications required to return the facility to operation have not yet been determined. The PG&E' t economic analysis filed on December 31, 1980 described a range of 1 modifications identified by a Bechtel Corporation study as potential backfit requirements. In addition to modification it is likely that most existing equipment would be overhauled and preoperational i performance tested before startup, and the plant would perform startup tests similar to a new plant. , j 13. Question 8(d): , Is there known deterioration of any components such that replacement 4 is contemplated in order to retain adequate standby conditions - in *
- order to achieve operational readiness? ,
1 Systems that are not needed in the cold shutdown mode are not being ( maintained, and consequently should be overhauled and tested as , above prior to operation. However, there is no known deterioration of any components such that replacanent is contemplated in order to retain adequate sta'ndby conditions, or operational readiness. i l 14. Question 8(e): . l Has state of technology advance to such an extent that any signifi-cant components on instrumentation and control systems will need to < be modified to achieve operational readiness? l The licensee has informed the staff that'it is not aware of any , t j instrumentation and control systems which would require modifica-3
- tion due to technological obsolescence, but may elect to do some modification because of the present day availability of improved
\( i
. l - _ . _ - _ . _ _ . ~ _ - . _ . _ _ _ . - _ _ _ - _ _ . - . _ _ _ _ . _ _ _ _ . _ . . . . _ _ _ _ - . _ -
. r *
- 12 - -
, , instrumentation. Some changes would be made as part of seismic e (
- upgrading which has already been started. The review of the acceptability of Humboldt Bay Unit 3 instrumentation with, respect to both seismic qualification and current NRC requirements would be
. considered by the staff prior to approving restart for the Humboldt '
Bay Power Plant. Unit No. 3.
% w. '
Vernon Rooney - Subs:ribed and sworn to before me this *?ti day of November,1981.
, '/ j, '*/ n E'fuz.
- Notary Public
$ connission expires:
A I , i G 6' .r-( Y e G 0 e e e e a e e e i O ( . e N e s -- - - - - - + . - . - - - =
, -~ , , , , _ . - ,- -,- ,.-- .---------,m-, -,--,---,ew-_w.---,-----,-,----c, - --- ,. - , - - . ~ . - - - , - --
VERNON L. ROONEY, JR. , , PROFESSIONAL QUALIFICATIONS , '( i I am a Senior Project Manager in the Division of Licensing Office of Nuclear Reactor Regulation of the U. 5. Nuclear Regulatory Commission. In this . position rqy responsibilities include management and coordination of matters related to license changes for operating reactors, and interacting with the licensee and the Office of Inspecti)n and Enforcement in matters related to
~
the safety of the plant. i I have been assigned as a Project Panager for operating reactors since I i joined the U. 5. Nuclear Regulatory Commissioa in October of 1972 except for a period of about a year in 1978 when I was assigned to the Reactor Safety Branch and performed technical reviews of operat' ng reactor license amendment l applications in the areas of core physics and thennal hydraulics. - 1 r ! I received a 8.5. degree with a major in chemical engineering from Leland University in 1951. I received an M.S. dooree in 1969 and a
- Stanford, Jr.in 1970 from the University of Arizona with a major in nuclear Ph.D. de!)ree engineer ng and a minor in physics. - -
I From 1951 to 1961 I was employeed by General Electric Company at Richland, Washington and was involved primarily in operation of.various Hanford pro . duction reactors and the Plutonium Recycle Test Reactor. In addition to reactor operating experience, this period also in'cluded experience in reactor production scheduling,' new reactor startup and testing, and major reactor modifications.
- k From 1961 to 1972 I was employed by the Atomics International Division of j
North American Aviation. I supervised the installation and operation of the . 4 SNAP 8 Experimental Reactor. This included direct rnanagement of the operating l and maintenance personnel from initial startup through final shutdown and dis-assembly of the plant. I was Lead Engineer for the postmortem analysis of the SNAP 8 Development Reactor and performed systems analysis and test planning for the Closed Loop Systems for the Fast Flux Test Facility. l l I am a member of the American Nuclear Society Physics and Operations Divisions. t e e ! l I . i 4 t [ -
. i
? . l l .
.-___..,.__.--.-,_-,_,._-.,-._~-..~,_j._..._..-,_..., . _ _ . . , _ _ _ , . _ _ _ _ , . _ . _ _ _ _ _ , . - . - _ _ _ . _ , , , _
. r ATTACHNE.'lT 1 4
I, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION , BEFORE THE ATOMIC SAF_ETY AND LICENSING BOARD _ ,
. t In the Matter of PACIFIC GAS AND ELECTRIC COMPANY ,
Docket No. 50-133 HUMBOLDT BAY POWER PLANT ) (Amendment to facility operating ' UNIT NO. 3 ) license) . AFFIDAVIT OF TOLBERT YOUNG JR. STATE OF CALIFORNIA ) COUNTY OF CONTRA COSTA ) SS I, Tolbert Young Jr., being duly sworn do depose and state as follows:
- 1. I am employed by the U.S. Nuclear Regulatory Comission in the
( Office of Inspection and Enforcement, Region V Walnut Creek, California. My professional qualifications are attached.
- 2. I am Chief, Reactor Projects Section 2 of the Reactor Operations l Project Branch, and have responsibility to direct the regional
- inspection program in the area of reactor operations at nuclear power plants, research and test reactors. I am the direct supervisor'of reactor operations inspdctors who have inspected the Humboldt Bay Power Plant.
- 3. I have read the Atomic Safety and Licensing Board's Memorandum and Order, dated October 21, 1981, regarding "Humboldt Bay Power Plant Unit No. 3 - Amendment to Facility Operating License". .
RegardingBoardQuestionsflumber2("Areapplicableregulatory requirements currently being met by licensee?") it is my
+ professional opinion, based on the inspections performed at the
. facility and with the exceptions of identified items of noncompliance or exemptions granted by NRC-fiRR, that the. licensee is currently meeting applicable regulatory requirements. The exemptions that .
I am aware of are described in Mr. Vernon Rooney's testimony,to be filed November 19, 1981. k msz W
/ 4. I have read the Declarations of Vernon Rooney, submitted in these \ proceedings and concur with the opinions and conclusions stated in each of the declarations.
I attest that the foregoing affidavit is true and correct to the best of my knowledge and belief. n t 'bl?:e l 'h'brY 'Y,
. T61bert Joung Jr.' "
Subscribed and sworn to before me . this /.7 # day .of h:' *J b , 1981 f1 pmmi....,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,o p .-' ' OFFICI AL SE AL
't. T* ) (4;
- JANET S. AND!i:5Off ,
[;/, No,ta y Public .
"ata;;;yp;c;cagiso,an.a c c u,,
My Comm. Esp ees Dec.7.1984 { @ C,1;*,8tl6tH,4el460 ell 044,,4,Htt46444.,64Hl444444404. l My Comision expires: O.7 d V b 6 e l e G k ( D
. r
- Tolbert Young *, Jr.
- Professional Qualifications Region V - Walnut Creek, California
, Office of Inspection and Enforcement .
My name is Tolbert Young, Jr. I am a Reactor Inspector with the.0ffice of Inspection and Enforcement, assigned to the Walnut Creek, California Regional office. -
.I have a Master.of Science Degree in Teaching in Mathematics. I received a B.A. in Mathematics and Physical Sciences from George Washington University in 1966 and my Masters from American University in 1%8 - both schools are located in Washington, D.C. .
I have a Professional Engineer certification in Nuclear Engineering from the State of California. .. , . I served 20 years in the U.S. Army, retiring in 1971. In 1961. I attended the U.S. Army Nuclear Power Plant Operators' Course. For the next ten years. I served in different capacities throughout the Arg's Nuclear Power' Program, qualifying as Equipment Operator, Control Room Operator, Shift Supervisor and Plant Superintendent. In 1966. I was appointed to the Training Division of that program and served in *
' progressively more responsible positions until 1969 when I was appointed as Chief Instructor of that Division. In my capacity as Chief Instructor, I was responsible for the training of students and operators in all phases
( of nuclear power plant operations and maintenance. In June 1971, I joined the then Atomic Energy Comission as a Reactor Inspector in the Region I, Newark, New Jersey Office. Since that time, I have been the principal inspector for over 15 research, test and power reactor facilities. From August 1972 to March 1974. I was assigned as principal inspector for the Vermont Yankee, Pilgrim 1 and Millstone 1 facilities, all Boiling Water Reactors (BWR). In June 1974, I was assigned as principal inspector for Diablo Canyon and was appointed resident inspector there in August 1978. In March 1981, I was reassigned to the regional office and became the principal inspector for San Onofre 2 and 3. In August 1981, I was promoted to my present position as Chief, Reactor Projects Section 2 Reactor Operations Project Branch. 4
' I have received the following special training:
! 1.* Fundamentals of BWR Plant Operations - 1972
- 2. 'BWR Technology 1973
- 3. Pressurized Water Power (PWR) Reactor Facilities 1974 '
, 4. PWR Refresher Training 1975 .-
- 5. PWR Simulator Training 1976
- 6. BWR Facilities 1976 t
4 q . l l
. . ~ '
ATTACHMENT 2 r, , RESULT 5' 0F INSPECTION _ EFFORTS IN 19_80__AND 1981 AT HUM 301.DT _ BAY .
.( ,
, (DN 50-133)' ,
. Inspection.of inspection '~.
.e Fum:Lfonal Area Dat,g M,a_n,ho u,r_3, ,Repp,r_t Nos. Results ,
Operational 5/20-22/80 34 50-133/80-02 Clear 4 .:5: ). ..: . . 10/26-24/81 23 Clear " i 50-133/81-05 . Safeguards.
- 11/19 71/79 18 50-133/79-03 Clear .
1%/15-18/80 32 50-133/80-05 Clear - 4/.06-09/81 - 27 50-133/81-02
- Clear .
N ttrials 5. . Accountabillty. 5/08(09/81.N. 2,.+..;.t 50-133/81-01.. 4y..',.-
- ~ Clear' d .t 4 04.L ': . 4.I
, -l .
y _
, : l .. v.'. T . '. e -
. .. ' . t .1::8 .
fica)th - 3/24-28/80 ;.l 38 r 50-133/80-0) ' Infraction. - Faildre'"' ;* Physics - 1 <: -
> t . * ' .:. to post high'Yadiation 1 ..
.. :v - .
i* area. . Y,' t - Q 4. g r. - W,.,. ..- Infraction '- Failure to
> t.; . .
control access'to pigh!
',,y.
.. ' t- } .p '),.,. r.: j.y : ;r ;... m,.
radiation ar' e a.4.: L,t Deficiency - Failure l to i.' .- .
- '7
- ':s- h.- label container.L. '
- 7. -
12/01-05/80 60{9: 50-133/80-04 Infraction-Failure;. to t D\ .? - - - complete shipping papers. 8/29 - 7/2/81 ' 34 50-133/81-03 Viol,ation - Severity
. Level V - Liquid waste
. systern vent monitor set to alarm at 100 mr/hr instead of 10 mr/hr. .
Special: 11/10/80 5 50-133/80-03 Clear ' To.Esamine i ~ Effects cf -
~
Eart h.1uake Oth:r; - Indeper. dent '10/17-22/81* 38 50-133/81'-04 Clear inspection: . Measurement Verification- ' (2 Announced inspection - all others were unannounced.) ,. O D t
-e 1 .
l * . [
Uli!TED STATES OF AMERICA HUCLEAR REGULATORY COMMISSION ( BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
~
In the Matter of . PACIFIC GAS AND ELECTRIC COMPANY - Docket No. 50-133 OLA (Humboldt Bay Power Plant Unit No. 3 Amendraent to Facility Operating Lictnse AFFIDAVIT OF INA B. ALTERMAN A;J
~
JEFFREY K. KIMBALL ON SEISMIC EFFECTS AT HUMBOLDT' BAY
- 3. Ina B. Alterman being duly sworn, state as follows:
- 1. I am employed by the U.S. Nuclear Regulatory Comission as a Geologist in the Geosciences Branch of the Division of Engineering ~, Offi,ce of Nuclear Reactor Regulation. A copy of g professional qualifications are attached and'are true and correct to the best of g knowledge and belief.
( I, Jeffrey Kimball, being duly sworn, state as follows: I am employed as a Seismologist / Geophysicist in the Geosciences Branch of, the Division of Engineering Office of Hu'elear Reactor Regulation. A copy of my professional qualifications are attached and are true and correct to the best of g knowledge and belief.
- 2. Question,4 in the Licensing Board's Memorandum and Order of October 20, 1981 stated:
- Has there been any evidence whatsoever of seismic effects within the exclusion area? If so, ple,ase describe. ,
The Staff's reply to this question is provided below. '. 1.
- 3. Since the licensing of the Hunboldt Bay' Nuclear Power Plant in 1962. two significant moderate seismic events have occurred in the site locality: one on June 7,1975, and the other on'Hovember 8,1980,'after the plant had been shut down by the NRC pending resolution of some faulting I
problems. The first of these, in 1975, had its epicenter 35 km south of Eureka, with an Mg =5.2, and caused significant damage in the region. There 1 were no geological or surficial effects of the earthquake within the exclusion area. The only known effects nearby were in the King Salmon Trailer Park, a half-mile west of the plant, where blacktop cracks occurred, and on a roadway
- one mile south of the plant in Fields Landing, where similar cracks were observed.
- 4. After the 1980 earthquake, which had an epicenter at least 60 km
- west of the California Coast on the sea floor, and an M =7, g a team of NRC, j - 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 l effects of the earthquake on plant structures was issued on January 19, l 1981 and later published in April 1981 as NUREG-0766 (" Effects of November 8 1980 Earthquake on Humboldt Bay Power Plant and Eureka California Area").
i t Conclusions of' tnis report were that the peak ground acceleration in' the I 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 1 the earthquake on Humboldt Bay Unit 3 were minimal and did not endanger the health and safety of the public. The 1975 earthquake had more energy associated with the higher frequencies than did the 1980 earthquake. In , ' general the 1975 event was of shorter duration compared to the far-field [ longer duration nature of the 1980 earthquake, qualitatively indicating !- less damage potential. 4 ( 4 I
- -,.-m ____,,---._.___.m-- _ _ _ _ _ - _ _ _ -,---,,__m- .------m.---
i, . .
- 5. Accompanied by our consultant, Tim Haitt of the USGS, Ina Alterman toured the plant site and region. No ruptures, or land slumps or slides of the ground surface were found within the exclusion area.of the plant. No evidence of surface effects of any kind were seen in the exclusion area or j on the marine . terrace, on which the plant is built, just outside the exclusion -
area. The surface effects closest to the plant were seen in King Salmon, again in the trailer park. There, new blacktop was freshly cracked, cne crack going through a concrete drainage box set into the. roadway. This location is near the projected surface trace of the Bay Entrance fault'. While the cracks do not suggest motion along the fault, it is interesting to observe that, further away, a number of cracks in the blacktop that suggested liquefaction were seen near a seafood stand on a road in Fields. . Landing that is also along the trace of the Bay Entrance fault. This was l( the same location as the Fields Landing crack observed after the 1975 , earthquake.
- 6. An open-file report by the U.S. Geological Survey (Lajoie and Keefer)M reports that the asphalt at one of the abutments of the highway bridge near the e'n trance to the plant was broken by two fresh cracks, a few millimeters wide, which the' authors attributed to slight displacement of the bridge during the earthquake. -
y . Lajoie, Kenneth and Keefer David " Investigations of the 8 November 1980earthquakeinHumboldtCounty,Cali.fornia,"(1981),USGSOpen ' File Report 81-397. - O
\
) .
The projected trace of the Buhne Point fault, dis' covered recently by PG&E' consultants' Summary Report of October 1,1980.2.] comes close to this bridge, but the USGS reported that no evidence was observed to , suggest fault rupture as the cause of the cracks.
- 7. The severest effects of the event within the plant region were in Fields Landing, where an M4 VII is interpreted.M Here houses were knocked off simple foundations, glass shattered, and some chimneys fell or were partially damaged. B,esides a few fresh cracks,in the roadtop previously mentioned and some fresh cracks in the sand quarry, no other geologic effects of the earthquake were observed. About 40 miles north of the plant, liquefaction-induced phenomena were observed on Big Lagoon Spit due east of the epicenter. These included sand boils, surface craqks, lateral spreads, and slumps at shoreline, in unconsolidated medium to
( coarse sand. Descriptions of other localities with minor surface disturbance resulting from the 1980 earthquake may be found in the USGS open-file report. y Woodward-Clyde Consultants, " Evaluation of the Potential for Resolving the Geologic and Seismic Issues of the Humboldt Bay Power Plant Unit 'No. 3. Surinary Report and Appendices " (prepared for Pacific Gas and Electric Company, Oct.1,1980). .
. (
y Ruth B. Simon, " Intensity Survey for 8 November 1980 Eureka, California earthquake," Seismological Society of America (Abstract). SSA meeting, March 1981. a e k i g 4 4
. 8. PG&E's geological and seismological consultants, Woodward- -
( Clyde Consultants, Inc. submitted a report in October,1980, referred to heretofore, describing the results of their geologic and scismic s,tudies of the plant site and region with special emphasis on the locations, regional relationships and ages of last movements of the faults.
. b Ina 8. Atterman
.ba ---%
1 Jeffffy tinb411 ' Subscribed and sworn to before me this //ed ^ day of ilovember,1981
. YO u 1'r W EAn.
- Notary Public j
. My conoission expires:0,, (g i e4sy
/ O O
e b 6 4 e O k D 6 h l
. _ _ _ ~ . _ _. _ _ . . _ _ _ . _ _ . _
e r INA B. ALTERMAN, PH.D.
. GEOSCIENCES BRANCH
~
- DIVISION OF ENGINEERING ;
U. S. NUCLEAR REGULATORY COMMISSION
- }- :
- My name' is Ina B. Alterman.and I am presently employed as a Geologist.in
, the Geosciences Branch, Division of Engineering. 0ffice of Nuclear. Reactor Regulation, Washington, D.C. 20555.
4
- PROFESSIONAL QUALIFICATIONS IhaveaB.S.inGeology(1963)whichwasawardedMagnaCumLaudefrom City College of New York, where I was also a member of. Phi Beta. Kappa. My ,
i Ph.D. in Structural Geolony was awarded in 1972 by Columbia University where ! j I held a Faculty Fellowsh<p. f tea Myprofessionalexperiencebe!anwithUnihersitkogy,chingandfieldand laboratory research. I taugh Introductory Geo Historical Geology, .. 1 and Optical Mineralogy in various colleges (City Hunter,.Barnard and Columbia) , as a part-time lecturer while in Graduate School.. As a full time Assistant Professor at Lehman College, starting in 1971, I also taught Structural Geology, i Tectonics, and Igneous and Metamorphic Petrology until coming to NRC in October, 1979. 4 My major research activities were grant-funded field mapping, structural analyses j of multiple deformation, mechanisms of ductile deformation, and ancient plate ~ tectonics. Some of this mapping, in Pennsylvania, is now included on the latest ] published by the Pennsylvania Geological officialgeologicmapofPennsyvania$977,Ididastudyoflinearstructuresand Survey. For two sumers in 1976 and f
- \ brittle fracturing of the earth's crust for the National Aeronautics and Space
- Administration using Landsat and other remote sensing techniques.
I,amoften'sentpapersonhariousaspectsofstructuralgeologytoeditand/or f review for journals and proceedings volumes (for example, Journal of Geology, i BasementTectonicsVol.). My own publications include. articles in the Earth Science Encyclopedia, Petrology Volume (still in press), articles on. stratigraphy, mechanisms of slatycleavage formation, Paleozoic plate tectonics in the Appalachian Piedmont an'd late brittle faulting in the Appalachians. ! At NRC I hahe been involhed in thershiew of'recent geologic features near Rancho i Seco, and at the Washington Nuclear Plant No. 2 on the. Columbia River Basalt
! . Plateau in Central Washington State. I recently supervised the compilation of j
information concerning the geoloflic and tectonic. setting for every nuclear facility 2 in California, including un' vers' ty and industrial research reactors and power . i plants. I am a member of the following professional gnd scientific organizations: I l Geological Society of America - American Geophysical Union . American Association for the Advancement of Science - New York Academy of Science F Potomac Geophysical Society " If Washington Geological Society Sirpa XI !(' Ph' Beta Kappa - s I F .. .. .
-.. - - ..- = - _ - -- -___. ---
/ -
1, . .- z
' JEFFREY K. KIMBALL' GEOSCIENCES BRANCH, P-314 . ./
( DIVISION OF ENGINEERING U. S. NUCLEAR REAGULATORY COMMISSION WASHINGTON, D.C'. 20555 .'
~ .
I Hy.name.is Jeffrey K. Kimball. I am employed as 'a Seismologist / Geophysicist reviewer, Geosciences Branch, Division of. Engineering, Office of Nuclear ' Reactor Regulation. I received a.B.S. degree in Oceanography from the. University of Michigan in 1977 and a M.S. degree in Geology from the University of Michigan in 1979, with a specialty in seismology and geophysics. I'bave been employed by NRC since May 1980 as a Seismologist / Geophysicist . reviewer as applied to the evaluation of applications for construction and operation of nuclear facilities, and to determine the thoroughness..of
~
this information for defining the seismic hazard for which facilities must-be designed. Since foi~ning the Nuclear Regulatory Commission staff, 'I have participated in the licensing activity for approximately ten sites. ,
- From 1977 to 1980, I was a research assistant and teaching assistant at' the University of Michigan. My activity as a research assistant included -
seismic data compilation studies for the U. S. Geological Survey and data analysis and operation of a nine station seismic network. My M.S. thesis work involved a study on surface wave dispersion of the Atlantic Ocean Basins [ and has been presented at national meetings of professional societies and published in a professional fcurnal. Teaching assistant experience consisted of helping teach both introductory and advanced geology field courses.in Uyoming for two su=ers and an introductory geology laboratory class at the
- University of Michigan. , ,_
I am a member. of the American Geophysical Union and the Seismological Society of A:arica, and h' ave co-authored 7 public'ations including abstracts of pre- - sentations to professional societies and NUREG documents.
~
k ( e I . l
~
e l ,;
.9
f '
. .I i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION "1 I' U ^ ATOMIC SAFETY AND LICENSING BOARD -
- U 2.4 w 9 Administrative Judges:
Robert M. Lazo, Chairman Gustave A. Linenberger David R. Schink , , _ , , , , _ ,
)
In the Matter of ) Docket No. 50-133-OLA
)
PACIFIC GAS AND ELECTRIC COMPANY )
) February 16, 1982 (Humboldt Bay Power Plant )
Unit No. 3 - Amendment to Facility ) Operating License) )
)
)
MEMORANDUM AND ORDER In a Memorandum and Order (" Order") entered on October 20, 1981, the Board directed the NRC Staff to provide written responses to a number of Board questions regarding the assertions of Pacific Gas and Electric Company (" Licensee") that Humboldt Bay Power Plant, Unit No. 3 "in its present cold shutdown condition, presents no risk to the health and safety of the public."M In compliance therewith, the NRC Staff filed its response by letter dated November 19, 1981 together with accompanying affidavits.
~
y See August 13, 1981 Response of Pacific Gas and Electric Company to Board Order of July 14, 1981 (page 6).
/3 prow? 6ef 09
-- = _
i ~ L. .
\ .I
~ 2 As permitted by the Order, the other parties have filed coments on the Board's questions and the Staff's responses. In their response filed on December 4, 1981, Joint Intervenors contend that the Board should
" revoke PG&E's operating license now and - order the plant permanently shut down and decomissioned regardless of whether, in its present cold shut-down condition, it presents an immediate danger to the public health and safety." (page 3)
Accordingly, in the view of Joint Intervenors, while the questions and answers are "of the utmost importance", they are "in a sense irrelevant to the issue presently before the Board in this proceeding, which is whether to allow PG&E to retain its operating license." ' 4 As for the Staff's answers, Joint Intervenors argue that they confirm that - the Humboldt Bay Nuclear Power Plant is in continuing violation of public health ~ and safety regulations and are rife with conclusional assertions for which no supporting data or factual bases areprovided. Therefore, Joint Intervenors urge the Board to find that the answers are inadequate and to order the Staff to respond more fully along the lines suggested in Joint Intervenors pleading of December 4,1981.
- In its letter dated December 9,1981 comenting on the Staff's answers to
. the Board's questions, Licensee i
" totally agree (s) with the staff that the current status of the plant is such that notwithstanding noncompliance with several existing NRC regulatory
- requirements, the plant in cold shutdown status poses no threat to the public health and safety."
Licensee concludes (as does the Staff) that unlike an operating plant,
- Humboldt Bay in a cold shutdown status does not require literal compliance with all the specific regulatory requirements currently in effect in order to assure adequate protection of the public health and safety.
" .J t ,
- 3 Accordingly, Licensee urges the Board to grant its motion to withdraw its application to restart Unit 3 and/or maintain the status quo pending determination of NRC back-fit policy and subsequent assessment by" Licensee of its impacts on the economic justification for restart of its Humboldt i
Bay nuclear facility. In this regard, Licensee noted that the Comission 4 was expected to issue for public coment a policy statement setting forth its proposals for establishment of a safety goal for all nuclear plants which would in turn form the basis for regulatory guidelines delineating l the precise standards which must be met for all plants including older plants such as Humboldt Bay. j The Board has carefully studied the answers provided by the Staff to the eight questions promulgated by the Board in its Memorandtsn and Order entered on October 20, 1981 and the coments provided by the other parties. , By and large, we are satisfied with the Staff's responses and find no reason for not accepting the Staff's belief that the public health and safety is being protected despite the fact that the Licensee has not complied with several existing NRC regulatory requirements. However, it is clear that the status quo at this shutdown facility ' cannot be allowed to continue indefinitely. The problem presented in this proceeding is that the Comission's regulations simply have never contemplated a long shutdown such has occurred with the Humboldt Bay plant. i The time has come to set a time-table for resolving that problem. As Licensee has noted, the Comission intends to establish a safety goal for all nuclear plants. The Comission has stated in U.S. Nuclear Regulatory Comission Policy and Planning Guidance 1982 published January 1982 (NUREG-0885, Issue 1)(pages 9-10):
~
4 Safety Goal Policy A. The Commission has decided to develop a safety goal and related safety guidance with initial emphasis on individual and Societal risks which might arise from reactor accidents. The purpose of this project is to develop a general approach to risk acceptability and safety-cost tradeoffs, and, to the extent possible, to specify qualitative safety goals and quan-titative safety guidance and standards for review of rules and practice. Planning Guidance
- 1. Simultaneously with obtaining public comment on safety goals, the staff should prepare for Commission review a step-by-step action plan describing how it intends to use the goals and numerical guidance within the regulatory process.
- 2. Qualitative safety goals and associated quantitative numerical guidance, when approved by the Commission, should be used in the evaluation of proposed and existing NRC reactor safety requirements.
, In accordance with its previously announced Plan for Developing a Safety Goal (45 FR 71023, October 27,1980), the Commission on February 11, 1982 published for public comment a proposed policy statement on safety
- goals for nuclear power plants. A report discussing the development of the proposed policy statement has been published separately as NUREG-0880, Safety Goals for Nuclear Power Plants: A Discussion Paper. Written comments on both are to be received by May 18, 1982. Meanwhile, the Commission has requested the staff to develop a specific action plan for implementation of the proposed qualitative safety goals and numerical guidelines. The plan, along with the public comments on the policy 4
st'atement and the discussion paper (NUREG-0880), will be considered
'O / r
)
5 by the Comission in reaching a final decision on the adoption of a reactor safety policy statement and its associated goals and guidelines. Once the NRC safety goals and implementing standards have been adopted by the Comission, the Licensee will require a reasonable period of time for review to assess the relative economic justification for returning the Humboldt Bay nuclear plant to service. We believe that six months is a - reasonable period of time for making a decision to resume operation of the plant or to decomission it. Meanwhile, regular quarterly status reports to the Board will be required. ORDER For the foregoing reasons and based upon consideration of the entire record in this matter, it is this 16th day of February 1982 ORDERED (1) That within six (6) months after the Comission reaches a final decision on the adoption of a reactor safety policy statement and its associated goals and guidelines, Pacific Gas and Electric Company shall report to this Atomic Safety and Licensing Board (a) that it is then ready to take actions necessary to permit resumption of operation of Humboldt Bay Power Plant, Unit No. 3, or (b) that it will then comit to the submittal l ~to the Comission of a plan to decomission the Unit.
- i. -
(,- i
+
6 (2) That on April 1,1982 and each three (3) months thereafter until this matter has been resolved, Pacific Gas and Electric Company shall file a detailed status report with the Board. FOR THE ATOMIC SAFETY AND LICENSING BOARD RJek M. L Robert M. Lazo, Chairn@h ADMINISTRATIVE JUDGE l t i i
- i-
%QQw
., ~-
.s
. So- m March 19, 1982
,/ ~. "
.\
~,\
e *
'b =
\
8j g .. . . . l ? . ..
,-) : .. :. . . . . . j s.
- MEMORANDIRI FOR: Harold R. Denton, Director Js rC -~ ,g Office of Nuclear Reactor Regula o.(
FROM: James P. Murray ' Director and Chief Counsel Rulemaking & Enforcement Division, OELD i StJBJECT: Petition Requesting Deccanissioning of Humboldt Bay Facility Ron Guenther, by petition dated February 20, 1982, has requested that the Comissin order the decomissioning at this time of the Pacific Gas
& Electric Co's Hurboldt Bay facility. ?!r. Guenther has set forth several reasons for his request, including the failure of the facility to comply with Comission seismic standards, the poor operating history of the facility, and several types of adverse environmental and safety impacts which would presumably occur if the facility resumed operating.
Mr. Guenther's petition was originally submitted to the Atomic Safety & Licensing Board sitting in the Humboldt Day case. In response to a . letter from Staff Counsel, Ifr. Guenther resubmitted his petition to your office. . This office will work with you and your staff to develop an appropriate response to the petition. Enclosed for your use are:
- 1. A copy of the petition; I
l 2. A draft letter of acknowledgnent; and
- 3. A draft Federal Register notice.
Please infonn us who your staff contact on this matter will be. l 9 S07 s l. James P. Murray Director and Chief Counsel Rulemaking & Enforcenent Division : . e ..... . Di s t . NRC Cent'.T.206 chron Cunningham (
Enclosures:
As stated: ELD Rdr Murray chr. Christ./ Sci rn4 TACT
- b ran Cvr. EID 8 I R,gi iI M Wp ' 'chron.RH/SB/DF/AG C
27269 o~.o . 0El. D.. ... .. . . . ... . .. . . . . . . . . . . . . . . ........................ ...................... ...................... ...................... ... su,,e , ..K .C.y r.:.mb..l...... .....egose40te7 820319 PDR AD0CK O5000133 lF e .
...... . 0,S,1,;. .3,,
g,,,,,,,,,,,,,,,,,,,, g ears) . 3f.1<yfg........ . . .. . G
.PDR . . . . . . ,,, , . , , , , , . . , , , ,
hr.0 F07.M 318 (10-80) NRCM 0240 OFFICIAL RECORD COPY uscro
- . . O y Q
. Certified Mail No. F22 9581932 .
Toeilarold Denton. . January 16, 1982 Director of Nucisar Beactor Esgulation U.S. Nuclear Begulatory Commissics Washington, D.C. 20555 29900 Highway 20 Fort Bragg, California 95h37 9 @ k..k'% . 70: Mr. Robert Iazo," Chaiman c3 Atomic Safety and Licensing had -p U.S. Nuclear Regulatory Commission . PETITION FOR DEC0F.W.ISSID :2 c, Washington, D.C. 20555 " g , g D 2D 1
~
Public Record - Humboldt Bay Nuclear Fower Plant Decomrdssio d g g' G 2 5 Lo g y g , Mr. Chairman and Embers of the Boards mc 77 t
'Ihis is a petitien for the decommissioning of the Humboldt Bay Nuclear Powe -
4 Fy reasons for petitioning the Board in this matter are as follows :
, 1) ne subject nuclear power plant is poorly and inadequate 2y designed for safe oper- -
ation, and has a long history of operating and safety failures deriving directly from design deficiencies.
- 2) 'Ihne earthquake faults have been discovered within h,000 feet of the ructor, and apprnpria'c a.lgn safety measures were not incorporated into either the reactor's *-
design or construction. he subject plant does not confom to the Nuclear Regula-tory Commission seismic standards. 2e cost of bringing the subject plant into compliance with these standards could exceed $300 million, corgared with estimated - decer.sissioning costs of $35 M111on. Decem=issiening is therefers the preferred econcr.ic ilternative. 4 .
- 3) The subject nuclear powe'r plant's ope' rating reccrd is among the verst in the histcry I
of nuclear power. The public has been presented with no convincing evidence that this sorry and irresponsible operating history will, er even can change for the bettere he latest evidence indicates that the utility will continue to operate the subject 'a plant in a negligent, irresponsible, and unsafe manner. ~ h) 2e utility has failed to comply with *an Atomic Safety and I.icensing Board order to - ' reveal hew the company expgsJ bring the subject power p3 ant up to; current Nu- . clear Regulatory Com ission/ptandards. This latest example of the utility's contin-uing reckless disregard for the public health and safety indicates plant decommiss-inning as the only practicable solution for problems of public protection.
- 5) ne subject power plant is one of the oldest commercial nuclear power plants under
- the Board's jurisdiction. It went on line in 1%3. Approximately 1/2 to 1/3 of the
- plant's life expectancy has elapsed. Decommissioning at this time would save future
. ratepayers substantial expenditures before embrittlement, increased residual radio-activity, and other safety problems beceme acute, ,and d'ecommissioning cos,ts rise l
dramatica13y. ,
- 6) Is the utility continues to engage in delaying tactics which prolong the process of i
solving public protection problems, it continues to maintain, and to protect the sub-i ject plant. Since 1976 the costs of maintenance have been approximately $15 million. s I Decommissioning the plant would eliminate at least maintenance problems for core l Icadings, and would cut the necessary costs of plant surveillance until the plant ' { could be either dismantled and moved to its final repository, or entombed in situ. l sma o.wm , + _ PDIPADOCK 05000133 cg. df [g&f 1 H PDR s
..v . . x. .
~' () )
Certi.fisd Pail N3. P22 9581932 - 4-
- 7) No perranent facility for safely disposing of the nuclear wastes deriving from '
the operation of the subject plant exists at this ti=e. This would include the approximately 35 tons of high-level waste now being stored at the plant site at substantial risk to the public health and safety in the area, dewnwind, and down-current from the site. -
- 8) Human population densities exist only a very short distance from the subject plant :
site. As exar.:ples, heavily travelled Highway 101 is only 1,500 feet from the reac-
,to r. There exists a nearby residential cors:: unity, beginning only 1/h mile from the plant. 'In case of accident, release of radioactivity from the plant would seriously endanger human life in the area. Additionally, cumulative losses of life could occur in areas downwind and downcurrent from the subject site.
- 9) Humboldt Bay is imediately proximate to the subject nuclear power plant site.
Safety problens inherent in the plant's radicactive discharges en sealife, and on the humn foodchain, have not been effectively recognized, evaluated, or dealt with. 3ank you for your consideration. I request your irediate action on this petitien for decomissioning. ' f - 1 -
.y . j
- Ron Ghenther .
D 0 me m m. en een e eame . * ** ** e G e-k
. em. a. w m..-- %-- _
e e
/
. 1 ( )
*e
+
e g 4 L I2 t. %
. s i
gg -
! < Q.
i3-i __t N v 9 3 0% as fqC u'7 2 U G: Q, am M
' *a 3 .
A4
- s. I 38 iyt -
g u e-4 e MEA,, s= 9 4.s Ope .* Ah5 2 3 I- f , 2244 AEd5
~
l I 1O an
,, s a 33 j8A A[t
.4 _
r ..
- k. ,
b
, (Draft) 1
~
Ron Guenther
. -29900 Highway 20 ,. Fort Bragg, California 95437
Dear Mr. Guenther:
This is to acknowledge receipt of'your petition, previously submitted to the Atomic Safety & Licensing Board, requesting that the Humboldt Bay
, facility be decommissioned. Your petition will be treated under 10 CFR 2.206 of the Commission's regulations. Accordingly, appropriate action will be taken on your petition within a reasonable time.
I enclose for your information a copy of the notice that is being filed for publication with the Office of the Federal Register. Sincerely,, Harold R. Denton, Director Office of Nuclear Reactor - Regulation
Enclosure:
As stated cc: "To licensee e k i
.,. em -+ + ,. w . -........w.. ......m. me- . . . + , . - . m = . - s==*= -- = -, - ~ = = * **
- s. .o . -
( i ) s.. y (Draft) 7590-01 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION [DocketNo. ] Pacific Gas & Electric Co. (Humboldt Bay Power Plant) Request for Action Under 10 C.F.R. 2.206 Notice is hereby given that by request dated February 20,1982, Mr. Ron Guenther petitioned the Commission to order the de:ommissioning of , Pacific Gas & Electric Company's Humboldt Bay facility. This petition is being treated as a request pursuant to 10 C.F.R. 2.206 of the Commission's regulations, and accordingly action will be taken on the petition within a reasonable time. Copies of the petition are available for inspection in the Commission's Public Document Room at 1717 H Street, N.W., Washington, D.C. 20555, and in the local public document room at the . Dated at Bethesda, Maryland, this day of March,,1982. For the Nuclear Regulatory Commission Harold R. Denton, Director Office of Nuclear Reactor Regulation e k
._ . . . . . . . . . . . . . _ _ . . _ ~ . . , . - . . . ..:.. . . . - . . . . . - - -
UG'.AS H. BOSCO 4< LAu=on eunuou
- 151 Disf2CT. Cat #04%4 *'5"'=GTON. D C 20U *
(202 225 3311) . COWITTEES Sulff 329 A =5=,. Congress of the 11nited States ,=== ( MERCHANT MARefeE SANTA ROSA CAUFORNIA 95404
>~ n>N = .
house of Representatiets o a >-' '" 2 "' POST OFFICE
^~a c~ "=' THE EUREKA INN
@ashington BE. 2cm 8 su'a =
77H & F STREETS EUREKA CAUFORNLA 95509
. (707 445-2055)
February 29, 1984 Mr. Nunzio J. Palladino - Chairman Nuclear Regulatory Commission 1717 H Street, N.W. Washington, D.C. 20555 Dear Mr. Falladinos The Pacific Gas and Electric Co. has indicated that it intends to submit to the Nuclear Regulatory Cousmission this spring a plan for decouanissioning the Humboldt Bay Nuclear Power Plant. Since this will be the first coassercial nuclear power plant to be decommissioned in the United States, I believe it is important that the utility's proposal be subject to a full and open discussion, including an analysis of potential alternative methods of decoussissioning the plant. I strongly urge the commission (- to require preparation of a full environmental impact statement and provide an epportunity for coussents by the public and interested agencies before making any final decision on PG&E's proposal. Your careful consideration of this request would be greatly appreciated. !. rdially, ! l DOUGLAS H. BOSCO Hember of Congress
.e i(
Q ? ! hl$ I ti - 9?GI rp f l
I h s ACrion ConTRot oATEs ConTRot so cou*t ocAot *
~3/26/N - 14178 3 Asp;*Desslas H. sesce YCaiu afety 1 __
oATc or ooCuuCsT
,o
- - - - - 2/23/34 flesAL HLPLY gowii ion s asAivar h irmes Palladi m , rite toCATion
- - ~
hclc7,",7,"c,,cc,,, OTHER _ _ _ _ _ DESCRIPTION ' LETTER O utuo O nt,Onr O OTHER SPECIAL INSTRUCTIONS OR REMARMS Orges properation of EIS and provide opportsatty ftr comments by the public hefere maktag flasl decisten en pG&E's PRIORITY prepasal for detaanisstentag Nunheldt Say l Asclear Plant l AS$ age *ED TO DATE INFORuAtlON ROUflNG q g,/
" * % men sfs/ma Dircks SCg M SECV-84-0262 tee 50Ae 1
#g /
mn
' t ;;n GCummingham NRC FORM 232 EXECUTIVE DIRECTOR FOR OPERAT[ok N PRINCIPAL CORRESPONDENCE CONTROL FOR THE COM"ISSION: Billie
( l - l I ,) (
$ 8 g
- s e
- 6 31-
/*
', \
~
CORRESP0CEl:CE C0!!TF.!*. ~'"V.ET Rep Douglas Bosco A; tw!: DER: 84-0262 LOGGIliG DATE: 3/5/84 0FFICE OF THE SEC'.ETARY ( ACTION OFFICE: EDO AUTHOR: , Rep. Douglas Bosco
, AFFILIATI0ft: -
LETTER DATE: 2/29/84 FILE CODE: AD6RESSEE: Palladino
SUBJECT:
Plan for decomissioning the Humboldt Bay Nuc Plant
--urges full EIS and period for public cornent ACTION: Direct Reply... Suspense: Mar 14 DISTRIBUTION: OCA to Ack p,c . ,.,. .., .-
....v.
-SPECIAL HANDLING: None Ti [ ',',' '/ *.
SIGNATURE DATE: FOR THE COMMISSION: Billie (
.=
.~
. ~
{
.L
- l
't
(' PACIFIC OAS AND E LE C T RIC C O M PANY 7GvG , 1o34 sixts sta ter . cua cn a, ca tiro n nia 95so t .<7o734432787 s.o. weens u., e sevCL8Ae PLAsef Opfea7%S eeuwe0LDf March 5, 1984 Office of Management Information and Program Control U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: Docket No. 50-133 License No. DPR-7 Gentlemen: Enclored sre the completed monthly report forms and the narrative of operaticg and major maintenance experience for Humboldt Bay Power Plant Unit No. 3 (HBPP-Unit 3) for February, 1984. These forms and the nar-rative are submitted in accordance with Section IX I.1.c of our Technical
.( Specifications.
Sincerely, E. D. Weeks Plant Manager Humboldt Bay Power Plant 1034 Sixth Street Eureka, California 95501 (707-443-2787) Enclosure ec: Mr. J. D. Shiffer Mr. B. S. Law Mr. J. O. Schuyler Mr. John B. Martin Regional Administrator U. S. Nuclear Regulatory Commission Region V I (f 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 - ( EDWeeks:me
$ttr3 Taco 7<s- g Pf' 35
a
. ,,i 4
MONTHLY NARRATIVE REPORT
.( OF OPERATING AND MAJOR MAINTENANCE EXPERIENCE e
This report describes the operating and major maintenance experience for the month of February 1984. This report was prepared by the Plant Staff and is submitted in accordance with Section IX:I.l.c. of the Technical Specifications. At the beginning of the reporting period, final core unload was in progress. The last spent fuel assembly was removed from the reactor on February 22. On February 23, the operating neutron sources were removed from the reactor. Also, on February 23, the lower drywell head was opened to prepare for removal of the in-core flux monitors. This work continued to the end of the reporting period. ( A 1 l h l .
.r.-
,. .i a OPERATLNG DATA REPORT (' DOCKET NO. 50-/33 DATE J- t- #4 COS1PLETED BY AJ. PEttA:.5 TELEPilONE 707/ v 4.7- 2 7 g y OPERATING STATUS
- 1. Unit Name:
Humeowr Bay Pown ilui-(Anr3 N*'cs
- 2. Rep'ortina Period:
- 3. Licensed Thermal Power (MWt): 22.0
- 4. Narroeplate Rating (Gross MWel: 6s
- 5. Design Electrical R:rins (Net MWe): 4s
- 6. blaximum Dependable Capacity (Gross MWel: 4s
- 7. Maximum Dependable Capaci y (Net MWe): 4S -
- 8. If Changes Occur in Capacity Ratings (Items Number 3 Through 7)Since Last Report.Gise Reasons:
</dl
- 9. Power LeselTo Which Restricted.lf Any (Net MWe): /I/I
- 10. Reasons For Restrictions,if Any: Al/A This Month Yr.-to Date Cumu!stise
- 11. Hoursin ReportingPeriod 0i0 /WO /8oV7/
- 12. Number Of flours Reactor Was Critical O o 9 6' / 7 /
- 13. Reactor Resene Shutdown Hours O O O
- 14. Hours Generstor On Line 0 0 9725'2.
- 15. Unit Resene Shutdown Hours O o O
- 16. Gross Thermal Energy Generated (MWH) O M /C 4/ 6, </56 o o %77T,732
- 17. Gross Electrical Energy Generated (MWH) ..
O o 4 534,151
- 18. Net Electrical Energy Generated (MWH)
- 19. Unit Service Factor O M ' 47.if2
- 20. Unit Availability Factor O o }y 9*/o
- 21. Unit Capacity Factor (Using MDC Net)
- o o I
- 9 *A
- 22. Unit Capacity Factor IUsing DER Net) o O 3 8.7 'A
- 23. Unit Forced Outage Rate O d /. 9/ #/e
- 24. Shutdowns Scheduled Oser Next 6 Months (Type.Dste.and Duration of Escht:
Af/A ~
- 25. If Shut Down'At knd Of Report Period. Estimated Date of Startup: DEC 0 ^'M' 5 f Io d /^/f3
- 26. Units in Test Status (Prior to Commercial Operation): Forecs>t Achiesed t INITIAL CRITICALITY INITIAL ELECTRICITY , ;
(. COMMERCIAL OPER ATION . PDR ADOCK 05000133 R PDR [ (9/771
- . . . . . . = - . . . - . . - .-
4 Fm A o ... DOCKET NO. I6-/O 3 - UNIT SIIUTDOWNS AND POWER REDUCTIONS UNIT NAME NBPp // 3
- ' DATE 1 9 */ '
COMPI.ETED BY # J 863EJCJ ,
- REPORTMON71f fed 4&AA.y
- TELEPilONE 7a7/VV3-7'7F 7 -
i w. 1 Licensee ,E*,
- Cause & Corrective I-
.I*E };; }Yg& - E ". Action to No. Date 3=
g$$ 5 j$go Event Report # uT N0 j Prevent Recurrence O
.S SV* Cs N / N/A - SE IS Ofic. moot Fic. A770NS 76-4 76070 2.
! l - 1 ! 4 4 l l i l ] j 4
- J 4 ,
i 1 2 - Method: Exhibit G Instructions - F: Forced Reason: for Preparation of Dita
- 1. Manual S: Scheduled A Equipment Failure (Explain) Entiy Sheets fur Licensee 2-Manual Scram.
B Maintenance or' Test Event Repunt (LI:R)l'ite (NUREG-C. Refueling 3 Automatic Scram. j 4-Other (Explain) 0161) D Regulatory Restriction ; E-Operator Training & License Examination 5 j F Administrative Exhibit I .Same Source G Operational Error (Explain) l (9/77) Il Other (Explain) ! i j .
.' e AVERAGE DAILY UNIT POWER LEVEL DOCKET NO. 60-/S3
-(. ' ungr H BPP M.3 DATE 3-/ ~ 8 N 8 ' I' N N COMPLETED BY TELEPHONE 707,NVS-27/7 MONDI EE8/IU4 U
~
DAY AVER AGE DAILY POWER LEVEL DAY AVER AGE DAILY POWER LEVEL (MWe Neti (MWe Neti . I O 17 2 18 3 19 4 20 5 21 6 22 7 23
~
8 24 9 25 10 26 Il 27 12 28 13 29 ',P 14 30 15 . 31 16 %f INSTRUCTIONS. ' On this format. list the average dai!y unit power leselin MWe. Net for each day in the reporting month. Compute to the nearest whole megawan. k 191771 - i r e
#9
- e i 1 y a C O MP.A.NY ELE C T RIC , (707) 443 2787
;CIFIC O.A.S .A.NSTREET D . EUREKA, C AllFo RNI A 9550:
m 1034 sixT H l)pJ}$ 4 c.man,
- o. awsActe w :xs
, m -. . . .x ,
ar . March 5, 1984 i Office of Management Informat ion on and Program Control V. S. Nuclear Regulatory Commiss Washington, D.C. 20555 Re: Docket No. 50-133 License No. DPR-7 forms and the narrative ofBay Power Pla Gentlemen: hly report Enclosed are the completed84.montnce experience for Humbold operating and major maintenaPP-Unit 3) for February,19with Section IX I.l.c _ c, Unit No. 3 (HBare submitted in accordance M ative CSpecifications. ince[ely, h;;.. cc y g ". 3ec 7 $y J. D. Weeks (Plant Manager Humboldt Bay Power Plant 1034 Sixth Street 95501 Eureka, California (707-443-2787) Enclosure cc: Mr. J. D. Shif fer Mr. B. S. Lew Mr. J. O. Schuyler Mr. John B. Martin ion Regional AdministratorU. S. Nuclear Regulatory Comm ( Region V1450 Maria Lane, 94596 Suite 210 Walnut Creek, California EDWeeks:me 3Y-,
" [ ,a
) ,_ MONTHLY NARRATIVE REPORT OF OPERATING AND MAJOR MAINTENANCE EXPERIENCE This report describes the operating and major maintenance experience for the abnth of February 1984. This report was prepared by the Plant Staff and is submitted in accordance with Section IX:I.1.c. of the Technical Specifications.
At the beginning of the reporting period, final core unload was in progress. The last spent fuel assembly was removed from the reactor on February 22. On February 23, the operating neutron sources were removed from the reactor. Also, on February 23, the lower drywell head was opened to prepare for removal of the in-core flux monitors. This work continued to the end of the reporting period. e
# D 6 1
e k a
- - . - - - - - . , ~ . - - - , - . . - . . - - , , . , , . , - - - .-- -.n- , m ,
4
. i 8
OPERATING DATA REPORT DOCKET NO. 80-/83 DATE J- t- #4 COMPLETED !!Y AJ PEO.5 TELEPilONE 707/VV& 27 B y OPERATING STATUS .
- l. Unit Name: NUMCowr EAv ?nwEr ?LAdT-(bhr3 N"'c'
- 2. Reporting Period:
3.. Licensed Thermal Power (MWr): 2 ~2- O
- 4. Nameplate Rating (Gross MWe): 6s
- 5. Design Electrical Rating (Net MWe): 86
- 6. Maximum Dependable Capacity (Gross MWe): 46
- 7. Maximum Dependable Capacity (Net MWe): sS -
- 8. If Changes Occur in Capacity Ratings (Items Number 3 Through 7) Since Last Report.Gise Reasons:
A/b1
- 9. Power Level To Which Restricted.if Anv (Net MWe): //!A
- 10. Reasons For Restrictions. If Any: N/A This Month Yr. to-Date Cumulatisc
- 11. Hours In Reporting Period ST0 /WO _/80V7/
- 12. Number Of flours Reactor Was Critical O O 96'l7/
- 13. Reactor Resene Shutdown llours O O O I4. Hours Generator On-Line O O 97267
- 15. Unit Resene Shutdown llours O o O
- 16. Gross Thermal Energy Generated (MWH) O o /6 4/ 6, :o M Type l oc>
--e nn u m" !
s,u 5 s.,o a t 2 x5 x E.r.= 8 - _,. _3. a- y e. s3=3 e Duration m c r. 4 e_ $ u a 4
.5 5 U -iQ RE p (Hours) 5*~ * 'n *
~s' E'a E.5 35. 3 2.E 0 E a}
q;; >-
;;i"
- r. ; -
s g Reason 3 ) m ;
"E.
u k*e o 5 ,
=
- 2. Method of '
.s- n s %
Shutting C
- 2 m Down Reactor 3 M
u
-4 C#9 E. y =
s m C
". 3 s
am r- O
-5 p E & g- 3 H 5,
=a na x &
it 0 > 7 t., d
- o
" Y' Y K System h m
o > r "X 2 C"d*4 g m M E E. $ $ l g 2 5 c c o- 2: M
= 2.1 ' ' h m
'x" E K2 y C Cornponent
'9-03
". n E Code 5 sa- o
,s 2 M
M Of
~~.
4 k. 1
-
- 0 w n 8 ommpm m
x Q n
- Yx m C E' ~<=44
- E ~ o -- 0 s>5 2 a e 2 dg E
-. X- *M7 a E~ D. E& @ M ag"O g -M Esc ES 24 3 "- g n . c- =
'O ZmHEO >O h 2 u -
es 3 3 g; m<mm.o c,D =. c, " E. a r r % 2 X 4 w ~ r R t *
- O E' O r. D O
a v hd m
- e. 3u c N g n Q u"3 h t . %
54 E z i y' M g
~
g b g %
@ D 4 x N M tM S m 4 ,
- o. % f M
A
t
- - AVERAGE DAILY UNIT POWER LEVEL .
)
DOCKET NO. 60-/S3 UNIT H BPP M3 DATE 3*/ ~ 8 4 COMPLETEDyY A*I NAD TELEPHONE 707,/WS-27/7 MONTH FEBRup n.Y DAY. AVERAGE DAILY POWER LEVEL DAY AVER AGE DAILY POWER LEVEL (MWe Net) (MWe Neti I O 37 2 gg 3 19 4 20
'5 21 6 22 7 23 8 24 9 25 10 26 11 27 12 28 13 29 ','
14 30
. 15 33 16 se INSTRUCTIONS .
On this forrnatolist the average daily unit power inelin MWe Net for e.ich day in the reporting inonth. Compute to the nearest whole inegawatt. (9/77i 4 4
? .
g40 6 Docket No. 50-133 i ( MAR 3 01984 Pacific Gas and Electric Company
- I 77 Beale Street, Room 1435 San Francisco, California 94106 .
Attention: Mr. J. O. Schuyler, Vice President
- Nuclear Power Generation., Licensing Gentlemen
~
j
Subject:
NRC Inspection, Humboldt Bay Unit 3 This refers to the routine inspection conducted by Mr. C. Sherman of this office on March 20-23, 1984, of activities authorized by NRC License
- No. DPR-7, and to the discussion of our findings held by Mr. Sherman with Mr. E. Weeks and other members of your staff at the conclusion of the
+ inspection. Areas examined during this inspection are described in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector. No items of noncompliance with NRC requirements were identified within the scope of,this inspection. i - ' In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the requirements of 2.790(b)(1). l l l l
~
l
- i. ,
i s _Nb ,
?u -
Pacific Gas and Electric Company 2 MAR 3 01984 I . Should you have any questions concerning this inspection, we will be glad to discuss them with you.
- Sincerely.
~
- 0. q . . , r;.
F t.. V. . . . F. A. Wenslawski, Chief
. Radiological Safety Branch
Enclosure:
Inspection Report - No. 50-133/84-01 cc w/ enclosure: P. A. Crane, Attorney PG&E P. O. Box 7442 San Francisco. CA 94120 J. D. Shiffer, PG&E S. D. Skidmore, PG&E E. Weeks. Plant Superintendent ( PG4E, Humboldt Bay Nuclear Power Plant 1034 Sixth Street Eureka, CA 95501 Distributed by RV: State of CA l Martin . bec w/ encl: P. Erickson, NRR ORB 5 t l S YUHA We ki GR . 3/1j/84 3/ft 4 3 4
~
i l
l
- Mg . ~
,' g UNITED STATES k NUCLEAR REIULATORY COMMISSION nEceN v l
l 1400 MARIA LANE,sulTE 210 WALleUT CREEK, CALIFORNIA 945s6 tooO
. MAR 3 01984 Docket No. 50-133 .
Pa*ific Gas and Electric Company 77 Benlo Street Room 1435 S m Fr:ncisco, California 94106 Attentica: Mr. J. O. Schuyler Vice President Nuclear Power Generation, Licensing Gentle:aen: Subj:ct: - NRC Inspection. Humboldt Bay Unit 3 This rafers to the routine inspection conducted by Mr. C. Sherman of this effica on March 20-23, 1984, of activities authorized by NRC License N2. DPR 1 7, and to the discussion of our findings held by Mr. Sherma.n with Mr. E. Weeks sua other members of your staff at the conclusion of the insp:ction.
! ., N Arcas cxamined during this inspection are described in the enclosed 'incp;ction report. Within these areas, the inspection consisted of selective cxacinationr of procedures and representative records, interviews with .perhonnel, and observations by the inspector.
t ,t ', Ni tt rs'of noncompliance with NRC requireme'nts were identified within the cqpa gf this inspection. u, i In'cceddacce with 10 CFR 2.790(a), a copy of this-letter and the enclosure will b3 placed in the NRC Public Document Room unless you notify this office.
"by tolcphone, within ten days of the date of this letter and evbmit written cpplication to withhold information contained therein within thirty days of th] d;te of this letter. Such application must be consistent with the r:quirements of 2.790(b)(1).
e y % .f 4 -- pp5 e 37-
,g a
- G
5 U. S. NUCLEAR REGULATORY C0!911SSION REGION V Report No. 50-133/84-01 Docket No. 50-133 License No. DPR-7 - Licensee: Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106 Facility Name: Humboldt Bay Unit 3 - Inspection at: Eureka, California Inspection conducted: March 20-23, 1984 Inspector: b - M C. Sherman, Radiation Specialist Date Signed Approved by: b Nti b . 3/48/%4 G. P. Y a Chief, Reactor Radiation Daf.e Signed Protec o Section Summary: Inspection of March 20-23,1984(Report:ji.. 50-133/84-01) Areas Inspected: Routine unannounced inspection of activities associated with Unit 3 decommissioning, radiological protection activities and transportation activities. This inspection involved 25 hours onsite by one inspector. Results: Of the areas inspected, no items of noncompliance or deviations were identified. e *
\
0 {0f
, - , . -- T- ..---. - --.--..,. -. ,--r
DETAIL
- l. Persons Contacted
( ,
*E. We'eks, Plant Superintendent
*R. Nelson, Power Plant Engineer -
*R. Parker, Senior Chemistry and Radiation Protection Engineer
*R. Lund, Radiation Protection Monitor Foreman
*B. Getty. Supervisor of Operations
*D. Peterson, Quality Control Supervisor ,
- Indicates those persons present at the exit interview.
- 2. Introduction Humboldt Bay Unit #3 has not operated since 1976. Transfer of all fuel from the reactor to the spent fuel pool was accomplished in the first quarter of 1984. The licensee's general plans for the facility are described in Inspection Report No. 50-133/83-03. A submittal from the licensee to include a formal decommissioning plan and request for a possession only license is expected shortly.
Based upon shutdown mode of the facility, this inspection focused upon items appropriate for the plant condition including surveillance requirements, radiation protection activities and transportation activities.
- 3. Technical Specification (T.S.) Required Surveillance
( The inspector reviewed surveillance required by Technical Specifications for the stack gas monitor, the liquid waste system vent and area monitoring system equipment. Records were reviewed for the period January 1983 to date. Surveillances were performed as specified in Section VII of facility T.S.. , With respect to the Stack Gas Monitor, T.S. Section VII.B.2 states that calibration, "shall be checked at least once per month." While the licensee performs this check according to Operational Test Procedure (OTP) fil, no provision for a check of response of the detector element to radiation is performed. Procedure OTPfil relies upon the reactor noble gas source term for verification of response and calibration. The licensee had used data from the last operating run in 1976 in calibration of the instrument. Additionally, the detector calibration factor is based upon a fresh noble gas mixture while the noble gas mixture expected at present would be essentially all Krypton 85. The licensee indicated that
' the gamma sensitive detector response to the Kr-85 would be significantly lower than expected for an operating situation, based on the low abundance of the Kr-85 gamma ray. This matter was discussed at the exit interview.
, The inspector reviewed records of tests performed pursuant to
' T.S.III.B.8 " Refueling Building Testing" for the period January 1983 to date. These tests are performed monthly in accordance with T.S.
( _ _m _e_m. e _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ . _ -
i ' 2 No items of noncompliance or deviations were identified. t ( 4. Technical Specifications . The inspector reviewed with licensee representatives. Technica.1 Specifications for Humboldt Bay Unit 3 in order to establish what operating limits, tests and surveillances were applicable to the facility in its present condition. Based on this review, the inspector noted that only a portion of T.S. requirements were still applicable to the facility mode of operation. - A summary of important conditions follows:
. reactor and drywell leak rate tests are not conducted;
. refueling containment is maintained and tested monthly;
. fuel storage conditions per T.S. V.B.7 are maintained;'
. reactor vessel water level monitoring is functional;
. other instrument channels and controls are secured or deactivated; radiation monitors are maintained in accordance with T.S. as required for shutdown conditions.
The inspector did not identify any conflicts' between the licensee position regarding interpretation of T.S. and the T.S. requirements based ( upon plant conditions.
- 5. Organization and Trainina The inspector reviewed the organization for radiation protection. The licensee organization remains as described in previous inspection report
,- 50-133/82-04. The licensee indicated that contract radiation protection personnel will be utilized during the next year to assist in decommissioning operations.
Plant operatione organization remains as required by T.S. IX.C. The licensee plans to maintain licensed personnel until T.S. are revised, however based upon T.S.IX.C.1, the licensee may operate such that licensed operators are not in the control room at all times but are on the site and the shift crew may be reduced from seven men to six men. The inspector noted that this position is consistent with T.S. IX.C.1.a,b,c.d.e and IX.C.3.b. The inspector noted that retraining for plant operating organization is conducted pursuant to T.S.IX.C.4.a and will focus on those elements that
. are appropriate for the plant's status. - -
z No items or noncompliance or deviations were identified. (
.m. ..
3 l
- 6. ALARA i
y The inspector reviewed activities condu,cted pursuant to 10 CFR 20.1(c)
- for maintaining radiation doses ALARA. The inspector reviewed minutes of the plant ALARA committee for 1983 and 1984 to date. The inspector also reviewed Radiation Control Procedure RCP-1B, "ALARA Personnel Exposure
~
Control" and selected ALARA review checklists prepared pursuant to procedure RCP-lb. Based on this review, the inspector concluded that the ALARA committee functions substantially in accordance with the procedure.
- 0 The inspector reviewed plant exposure summary records for 1983. Total exposure for plant staff and visitors was 14.54 ren. The maximum exposed individual received 1.225 rem.
No items of noncompliance or deviations were identified. I
- 7. Radiation Protection Program
- a. Records. The inspector reviewed selected plant records for individual radiation exposures. Determination of current calander quarter doses for visitors was verified. Individual records on NRC-5 equivalent forms were also reviewed. Based on records review and review of exposure summary for 1983, no exposures in excess of regulatory requirements were identitled.
The inspector noted that documentation of exposure when film badges were lost was minimal. RCP-1A specifies action when personnel
, dosimeters are lost or damaged, including pencil dosimeters but does
- . not specify what action is to be taken if a pencil dosimeter is damaged or offscale. This matter was discussed at the exit interview.
- b. External Dosimetry. The inspector verified that the licensee makes f
provision for positioning the whole body dosimeter in the location of highest expected dose. The inspector also noted that extremity dosimetry is also issued on some occasions and that the location required for the dosimeter is specified on the Special Work Permit (SWP) as stated in u RCP 1A.
- c. Su rveys. The inspector reviewed records of daily 'A' surveys performed in December 1983 and 'B' surveys performed at various intervals for the period January 1983 to date. 'B' surveys are a comprehensive record of radiation exposure rates and contamination levels in the facility.
The routine surveys reviewed did not indicate detailed survey data for penetrating and nonpenetrating dose rates in close proximity to l equipment. Special Radiation Surveys are (SRS) are documented on l SRS forms. The inspector reviewed selected forms for the period
- January 1984 to date. The majority of these forms are used to document
' unconditional release surveys. A review indicated that only a small fraction of these surveys are used to document radiological conditions for special work evolutions. The inspector reviewed special work permits (SWP) for March 1984 and selected SWP's for 1983. With
( respect to this review, the inspector noted that SWP's generally did not provide detailed survey data but rather indicated whether dose l _
u . 4 s l rates were ' greater than 100 mR' or 'less than 100 mR'. In most cases SWP's did not reference SRS data. The inspector noted that
, the licensee's submittal dated _ March S.--1921, referencwd lu I.o.
~
IX.M.Ipecifies that. ('All necessa'ry surveys are made prior to issuing the petuit and unusual radiation levels are also indicated on the permit." t . The inspector also discussed with licensee representatives the need to document surveys pursuant to 10 CFR 20.401(b). This matter was discussed at the exit interv'iew. w ys gfu,,9 5 No items of noncompliance or deviations were identified.
- 8. Transportation Activities The inspector reviewed records of three shipments of approximately 3,000, 10,000 and 4,000 curies of radioactive material each. Shipments were examined for compliance with 49 CFR and 10 CFR 71. ~
The shipments were made in accordance with written procedures and were reviewed by the site quality control supervisior. The shipments consisted primarily of activated stainless steel and zirconium reactor components including control rod blades. Based on this review, the inspector concluded that shipments were made in accordance ~ with applicable regulations. No 1,tems of noncompliance or deviations were identified. t -
- 9. Audits l The inspector examined Audit #84068P performed February 22 to March 1, 1984 by the PG4E corporate quality assurance function. This audit appeared to be comprehensive, and to cover in depth selected aspects of
. conformance to radiation control program procedures. The audit l
identified several problems including potential noncompliance with the 1 technical specification requirement for area monitor alarm set points. In this case the licensee took prompt corrective action to reset alarms. The inspector also reviewed onsite quality control reviews of radioactive material shipments described in the preceeding paragraph of this report and a radiation protection audit completed in May 1983. The inspector verified that Nuclear Plant Problem Reports issued as a result of their audit were resolved. Minutes of the plant staff review committee (PSRC) were reviewed for the period June to December 1983. The committee appears to be functioning as required by technical specification. . s No items of noncompliance or deviations were identified. ee e-># q _.--_.._,_y - -_v-._ . - . - , , - - - - _ . _ , , _ . - - , , , . - - - _ _ - - - _ - - .
1
- 5 a .
- 10. Exit Interview
( The inspector met on March 23, 1984 with the individuals denoted in paragraph one of this report. The insp'ection scope and findings were f' discussed at that tLae. ,
- i With respect to the stack gas monitor, the licensee representa_tive .
indicated that the matter would be addressed in a submittal to the NRC for decommissioning. , a With respect to documentation of surveys, the inspector discussed his observations and noted that similar observations were made in previous Inspection Report No. 50-133/82-04. The inspector. reviewed regulatory ~ requirements in this area with site management. The licensee stated their intent to review this area promptly. The need to better document exposure evaluations for lost film badges or off scale pocket dosimet?ps was also discussed. . 1 e l l 1 o i-I 0 _,I. ,.,,y, , - ,.._ _ _ .. . -
[oc..gg 6-4f'c.Ia( UNITED STATES 4 8. c y
..r.
NUCLEAR REGULATORY COMMISSION
.. I REGION V 1450 MARIA LANE.SulTE 210
,o' WALNUT CREEK, CALIFORNIA 94596 I
AUG.2/.DH Docket,No. 50-133 Pacific Gas and Electric Company 77 Beale Street Room 1435 San Francisco, California 94106 Attention: Mr.'J. O. Schuyler, Vice President Nuclear Power Generation Gentlemen:
Subject:
NRC Inspection - Humboldt Bay Unit 3 This refers to the routine inspection conducted by Mr. E. M. Garcia of this office on July 23 through 27, 1984 of activities authorized by NRC License No. l DPR-7, and to the discussion of our findings held by Mr. Carcia with Mr. Weeks ( and other members of your staff at the conclusion of the inspection. Areas examined during this inspection are described in the enclosed I inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector. Based on the results of this inspection, it appears that certain of your activities were not conducted in full complian::e with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix A. Your response to this Notice is to be submitted in accordance with the provisions of 10 CFR 2.201 as stated in Appendix A. Notice of Violation. The findings,of this inspection as identified in the Notice of Violation and i Inspection Report indicate to us the need for additional management attention to your internal radiation exposura control program. We are concerned that the ingestion incident referenced in the Notice of Violation and Inspection Report may be symptomatic of a breakdown of your program. We therefore believe it would be of value for you to reflect upon the circumstances that resulted in this incident. Accordingly, in addition to your reply to the attached Notice of Violation, you should describe those actions taken or. planned to improve the effectiveness of your internal exposure control program. We will rev.iew your reply to this letter and the Notice of Violation in determining whether early reinspection or other actions by our office may be necessary. cz v, t !WL] , . - N$/ 0 + C%7 }y
l Pacific Gas and Electric Company 2 gyQ 2, { {}gf ( In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within the thirty days of the,date of this letter. Such application must be consistent with the requirements of 2.790(b)(1). Should you have any questions concerning this inspection, we will be glad to discuss them with you. The response directed by this letter and the accompanying Notice are not ! subject to the clearance procedures of the Office of Management and Budget as t required by the Paperwork Reduction Act of 1980, PL 96-511. Sincerely,
. d Ross A. arano Director, Division of Radiological Safety, Safeguards, and Emergency Preparednes Programs
Enclosure:
A. Notice of Violation
/ B. Inspection Report No. 50-133/84-03 cc w/ enclosure:
. S. D. Skidmore, PG&E E. Weeks, Plant Manager (Humboldt Bay)
Dick Vollmer, NRR P. A. Crane, Jr., Attorney, PG&E C. M. Seward, PG&E J. D. Shiffer, PG&E State of CA
\
1-APPENDIX A NOTICE OF VIOLATION 4' Pacific Gas and Electric Company Docket No. 50-133 77 Beale Street, Room 1435 San Francisco, California 94106 License No. DPR-7 Inspection Report No. 84-03 l
.As a result of the inspection conducted on July 23-27, 1984 and in accordance with the NRC Enforcement Policy 10 CFR Part 2. Appendix C, the following violations were identified: - i A. 10 CFP 20.201(a) states "As used in the regulations in this part.
" survey" means an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions. When appropriate, such evaluation includes a physical survey of the location of materials and equipment, and measurements of levels of radiation or concentrations of radioactive material present". 10 CFR 20.201(b) states in part that "Each licenses shall make or cause to be made such surveys as are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present". 10 CFR 20.103 prescribes intake limits of radioactive material by individuals.
Contrary to this requirement, on December 13, 1983, the licensee permitted four individuals to cut into and open the resin return lines of the Resin Storage Tank without first making an appropriate survey or measurement to evaluate the extent of airborne radioactive material that would be released when the lines were cut. When the lines were cut airborne licensed material was released which resulted in exposure to j three individuals. These individuals received an intake equivalent to 150, 75, and 50 MPC-hours respectably. l This is a Severity Level IV Violation (Supplement IV). B. 10 CFR 20.203(f)(1) states "Except as provided in paragraph (f)(3) of this section, each container of licensed material shall bear a durable, clearly visible label identifying the radioactive contents". Contrary to this requirement, on July 24,1984, a 55 gallon drum located at the +12 foot level of the Reactor Building and four boxes located in the Radioactive Waste Storage Yard contained licensed radioactive material and were not labeled as required. This is a Severity Level V Violation (Supplement IV). Putsuant to the provisions of 10 CFR 2.201 Pacific Gas and Electric Company is hereby required to submit to this office within thirty days of the date of this Notice, a written statement or explanation in reply to Items A and B including: (1) the corrective steps which have been taken and the insults achieved; (2) corrective steps which will be taken to avoid further violations; (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good esuse shown. ( p
n Appendix A, Notive of Violation 2 P.Uc0<1004 wa. s . *.; ~n I ' The response directed by this Notice are not subject to the clearance procedures'of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511. ~ hbb w Dated G. P.'Y fasj' Chief Reactor Mation Protection Section ( l I r 1 G . i ( \ r -
U. S. NUCLEAR REGULATORY COMMISSION ( REGION V Report No.:*50-133/84-03 Docket No.: 50-133
. License No.: DPR-7 Licensee: Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106 Facility Name: 'Humboldt Bay Unit 3 Inspection at: Humboldt County, California Inspection conducted: July 23 through 27, 1984 Inspector: _
E.
. E h/- 21/$iff M.' Garcia, Radfation Specialist Date Signed Approved by: b _
ben 8/SV/fpl G. P. Tuha s, Chief, Reactor tate Signed Radiatida_ Protection Section ' Summa ry: Inspection on July 23 through 27, 1984 (Report No. 50-133/84-03) Areas Inspected: Routine unannounced inspection by a regionally based inspector including status of the decommissioning plan; internal exposure control; waste classification; transportation; followup on IE Information Notices and Licensee Event Reports; Audits; and facility tour. This inspection involved 36 hours on site by one inspector. Results: Of the eight areas inspected Violations were identified in two areas (failure to conduct adequate surveys - Paragraph 3; failure to label containers of radioactive material - Paragraph 9). t t (
'6"C'l!%2T $ ff
\
l
' I DETAILS
- 1. Persons Contacted
- a. Pacific Gas and Electric Co. Staff
*E. D. Weeks, Plant Manager *
, *R. T. Nelson, Power Plant Engineer ~
*D. A. Peterson, Quality Control Supervisor J. F. Gerace, Administrative Supervisor
*R. C. Parker, Senior Chemistry and Radiation Protection Engineer M. J. Fowler, Training Coordinator R. M. Lund, Foreman, Radiation Protection Monitors
- b. Contractor Staff R. F. Decker, Radiological Engineer (Cheerad Corporation)
- Indicates those individuals attending the exit interview.
In addition to the individuals noted above, the inspector interviewed other members of the licensee's staff.
- 2. Decommissionina Plan Previous inspections (see Inspection Reports 83-03 and 84-01) have discussed the general plant status and general plans for the decommissioning of the facility. As those previous reports indicate the licensee intended to submit the formal decommissioning documents in the
( first quarter of 1984. At the time of the inspection these documments had not been submitted. The licensee indicated that the delay in the submittal was due to other time consitments on the licensee's staff and not due to any
- unexpected complications.
The decommissioning documents are completed and receiving final in-house licensee review. The plant staff projects that the documents will be submitted by the end of July 1984. The documents prepared consist of (1) I SAFESTOR Decommissioning Plan (SDP), (2) Environmental Impact Report, (3) new proposed Technical Specifications for the possession license, (4) a new Quality Assurance Plan, and (5) a preliminary Dismantlement Plan for 30 years after SAFESTOR. The licensee's staff was assisted by Bechtel.Nationel Corporation of Oak Ridge, Tennessee in preparing these documents. 4 The SDP is written from the perspective that those tasks that can be done under the current license will have been completed prior to beginning
'with this plan. These tasks include treatment and disposal of '
contaminated water and resins, removal of " hot spots" from non required systems, and the shipment of stored radioactive waste. The licensee
- estimates that there are about 24,000 curies of activity in liquid and solid wastes. Additionally, the licensee estimates an inventory of 25,000
' curies in components and structures, not counting the spent fuel. !,(
4 4
-w -r-..., -- , . . . - . . . - . , . - r.,_ ._m.,. , . , . .-. ,..._,---r-.,..m,,w.-,,__.m_.m, #-.. ---.. , 3 -r---- - - - . - -
2 The licensee is aware that the Humboldt Bay Nuclear Power Plant subcommittee of the Advisory Committee on Reactor Safety plans to tour the plant and hold hearings on the SDP in September. - (- No Violations or deviations were noted in this area.
- 3. Internal Exposure Control .
The inspector reviewed the licensee's controls of internal oecupational exposure and internal exposure dosimetry to verify compliance with the requirements of Part 20. The following related procedures were reviewed:, Identification Title Revision 6 RCS-2 Internal Dose Control . 6 i RCS-5 Medical 5 RCP-1B ALARA Personnel Exposure Control 51 RCP-2A Personnel Internal Exposure Control 70 RCP-2B Evaluation of Intakes of Airborne Radioactivity 70 RCP-2C Calculation and Recording of Airborne 45 Radioactive Material Exposures 4 RCP-2D Bioassay Program 53 ( RCP-12A Issuing and Returning Respirators 69 The inspector also examined selected records of respiratory protection training, respirator fitting, medical examinations, and Airborne and Controlled Area Entry Logs. Based upon this review the inspector made the following comments:
-~,7 j a. 1 CFR 20.203(c)(2) equires that certain prerequisites before an in idual is pe ted to use a respirator. The inspector did not identiff'aEp instances where these prerequisites had not been accomplished. However, the licesee's program lacks the degree of formality necessary to arsure that on any given day a respirator user has fulfilled all prerequisites.
- b. Copies of physician certifications of an individual's ability to use a respirator were not available on site. This is not consistent with the licensee's RCS-5, " Medical".
- c. The paragraph titled Scope of RCP-1B "ALARA Personnel Exposure Control" does not include consideration of internal exposure control. Further, the body of the procedure does include considerations for limiting ingestion of licensed materi'a1.
( l 1
- - - - - - - - - - ,,...-,---nc - .~--,..,---.,-..-e- --,-n---,-_-,_,,e.<,w,. - . -, , - . w r , w. g - - , - , . , - -.nr,-,, - --
. 3 i
l
<* Respiratory Protection is included in the ALARA Review Checklist, but completion of this checklist is not required. These deficiencies were present in this procedure at the time of the inspection, seven months after the incident described below.
The inspector examined records and interviewed personnel associated with an airborne contamination incident. The incident occurred while modifying the Resin Storage Tank to be a laundry waste stora~ge tank. This tank and associated lines are part of the system used to regenerate the resins used in the Reactor Coolant Demineralizer System. This modification had been designed, reviewed and approved under Design Change Request (DCR) HB3-0-SM-111. This project was reviewed and approved by the Plant Staff ALARA Committee in their December 6, 1983 meeting. The i minutes of this meeting indicate that the potential for external exposure was discussed and evaluated; external dose goals were established for the job. The minutes do not record any surveys, evaluations, or discussions of potent.ial airborne contamination problems. An ALARA Review Checklist was not prepared for this job. No engineering controls, special precautions or respiratory protection equipment was directed to protect the workers from the potential airborne contamination. The Senior Chemistry and Radiation Protection Engineer stated that at the time of the ALARA review, the potential for airborne contamination was evaluated, but not considered likely. Their prior experience made them believe that the system would be wet and thus not likely to generate airborne contamination. The system was internally contaminated and had not been in use for about six years. i On the morning of December 13, 1983, four individuals were working in the Condensate Demineralizer Regeneration Room. The Special Work Permit ( (SWP) for this day's work was number 25162. The work to be done under j this SWP was to remove the cover of the Resin Storage Tank and wash the , tank out. Before the cover could be removed the resin return lines had to be dismantled from the top of the tank. This SWP did not require respiratory protection equipment, engineering controls to reduce airborne contamination, or analysis of an air sample immediately following the opening of the system. According to the individuals i ^ present, when the first return line was cut through " sandy, dusty" material started to fall out and became airborne. After some attempts to catch the effluent in a bucket and to relocate an air sampler closer to the breathing zone of the workers, the Radiation Protection Monitor temporarily stopped the job and went to get respirators for all involved. The airborne concentration was not determined, nor were the individuals surveyed before the respirators were don. After donning i l respirators the work in progress was completed. The individuals were
" frisked" when they exited the radiological control area, and were detected as being contaminated. Based on whole body counts and air '
i i sample data the licensee estimates these individuals received an intake of radioactive materials equivalent to 2, 50, 75, and 150 MPC-hours respectably. l 4 I l '( i l l l l \ . l __ .n l
. 4 10 CFR 20.103(b)(2) states in part that, "Whenever the intake of radioactive material by any individual exceeds this 40-hour control measure, the licensee shall make such evaluations and take such actions I as are necessary to assure against recurrence. The licensee shall maintain records of such occurrences, evaluations, and actions taken in a clear -and readily identifiable form suitable for summary review and evaluation". The results of the licensee's assessment are noted above.
This assessment is consistent with Regulatory Guide 8.9, " Acceptable Concepts, Models, Equations and Assumptions for a Bioassay Program". The licensee's documented actions to assure against recurrence consisted of including the topic _of Airborne _Situa_ti_ons in the_ annual radiation
.prgtection training. This was one of five major topics presented. The training session given to general employees lasted fifty minutes, the one given to supervisors twenty minutes. The licensee stated that the -
incident had also been,_ discussed at a department head meeting and with
,the__maintenmace and radiation n-at.ction perannnel. Region V concludes that the action taken to assure against recurrence met the letter of the regulation.
10 CTR 20.201 requires that "Each licensee shall make or cause to be made such surveys as are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present". The extent of the radiation hazard under the specific set of conditions of this job were not properly evaluated, in as much as the potential for airborne contamination had been rejected when in fact a substantial hazard did , exist. This is a Violation of NRC regulations (50-133/84-03-01). This matter was discussed during the exit interview. The licensee stated that at the time of the ALARA evaluation they considered the possibility g that the system was contaminated but did not feel that it was. Furthermore every time a SWP is prepared the need for respiratory protection is consider. The licensee also stated that they recognized, in hindsight that they did not do an adequate review, but at the time they did not anticipate the problem. Regarding procedure RCP-1B "ALARA Personnel Exposure Control", they agree that the procedure needs to be improved and provided the inspector with a draft of the revision.
- 4. Waste Classification The inspector discussed the status of the licensee's program to meet the requirements of Part 61 and 20.311. The licensee representative stated that no. procedures,have been vet been written to meet these regulations.
Review of shipping records and interview with the licensee's staff indicate that no radioactive waste has been shipped since the waste classification regulations became effective. The licensee was reminded that their program to meet Part 61 and 20.311 must be in place prior to
. any further shipments of radioactive waste. They stated that they are well aware of these requirements.
No Violations or deviations were identified in this area. , S
5 s
- 5. Transportation The inspector examined records of shipments of radioactive materials made
( by the licensee from December 21983 to the time of the inspection. The records were examined for compliance with 49 CFR and 10 CFR 71. The licensee had made five shipments, records number 356 through 359. The number 356 had been inadvertently used for two dificzent shipments. The licensee does not keep a sequential log of shipments made. New shipment numbers are determined by looking in the file for the previous shipment number. These five shipments consisted of resin samples, calibration standards, and special tools; the record does not indicate any radioactive waste shipments for this period. A Type 7A container that had been designed and tested by the licensee was used to ship resin samples. Review of records indicate that the package meets the.t ign requirements of 49 CFR 173.412. This same design was to be used in two additional shipments that were ready for shipment. The inspector observed that these packages were not marked with the exact proper shipping name as listed in the Hazardous Materials Table 49 CFR 172.101. The licensee promptly corrected the markings. Based on this review, the inspector concluded that shipments are being made in accordance with applicable regulations. No Violations or deviations were identified in this area.
- 6. Followup on IE Information Notices
( The inspector reviewed the licensee's records to determine if the following Information Notices had been received and reviewed:
- a. IN-82-43 " Deficiencies in LWR Air Filtration / Ventilation Systems".
- b. IN-82-49 " Correction for Sample Conditions for Air and Gas Monitoring". '
- c. IN-82-51 "Overexposures in PWR Cavities".
- d. IN-83-10 " Clarification of Several Aspects Relatin'g to Use of NRC-Certified Transport Packages".
- e. IN-83-14 "Dewatered Spent Ion Exchange Resin Susceptibility to Exothermic Chemical Reaction."
- f. IN-83-21 " Defective Emergency-Use Respirator".
3 IN-83-33 " Nonrepresentative Sampling of Contaminated 011".
- h. IN-83-52 " Radioactive Waste Gas System Events". -
s
. - _ _ _- _ - - _ - _ .. . _ . - - _ .= _ __- -
0
- i. IN-84-34 " Respirator User Warning: Defective Self-Contained Breathing Apparatus Air cylinders".
I
- j. IN-84-40 " Emergency Worker Doses".
These,Information Notices had been received and routed for review to cognizant staff members. These notices were also listed in the.NRC ' Correspondence List which is included in the Plant Safety Review C6mmittee agenda. No Violations or deviations were identified in this area.
~
- 7. Followup on Licensee Event Report (LER)
! (Closed) 84-01-LO, Gas Treatment Flow Control Valve Linkage Failure. The inspector reviewed this LER and the records of the corrective action taken. The inspector concluded that the licensee's review, corrective actions, and report are adequate and in conformance with regulatory requirements. i No Violations or deviations were identified in this area.
- 8. Audits The inspector examined the report of audit # 84078P performed March 26 i
through 29, 1984 by the licensee's corporate quality assurance } organization. This audit examined the implementation of plant i procedures for environmental radiological monitoring, and 10 CFR 50, i Appendix B Criteria XIII and XIV. The inspector's review of the audit i ,( report was limited to the environmental radiological monitoring portion. Review of the qualifications and training of the auditors involved did not identify special knowledge or training in radiological environmental radiological monitoring. The licensee stated that the extent of the audit, in this area, was to verify procedural compliance, and auditors with special knowledge or training in environmental radiological monitoring were not required. The licensee informed the inspector that a management review (plant quality control) of the radiation protection department was planned for the third quarter of 1984. The emphasis of this review will be on compliance with Regulatory Guide 4.15 " Quality Assurance for Radiological Monitoring Programs (Normal Operations)- Effluent Streams and the Environment". No Violations or deviations were identified in this area. 1
- 9. Facility Tours
,On July 24, 1984 the inspector toured the radiologically restricted areas of the facility making independent radiation measurements with a portable
' ionization survey instrument (Victoreen 470A, NRC No. 008949 calibrated January 10, 1984) to determine compliance with the regulatory . . requirements on posting, labeling and control of radiation an'd l stadioactive materials (10 CFR 20.203, Technical Specification IX.M). l ( _.w-o-- __ ,___..m._--.,m_-_____._,m--%_ ,_--,y--,,- -,- _ .. , - - - . ---.w-,
7 During this tour the inspector observed good agreement with the radiation levels measured by the licensee representative. Radiation areas were properly posted and appropriately controlled. Personnel contamination ( survey instruments were working properly. 10 CFR 20.203(f) requires that containers of licensed material. bear a durable and clearly visible label identifying the radioactive contents. These labels are not required if the quantities contained are less than those listed in Appendix C of Part 20, contain only natural uranium or i thorium in quantities less than 10 times those listed in Appendix C, the concentration are less than those listed in Appendix B, Table I, Column 2 of Part 20, are being attended by an individual, are in transport, or are only accessible to individuals authorized to use them, provided that the contents are identified to such individuals by a readily available i written record. During the tour previously discussed the inspector detected radiation emanating from a 55 gallon drum at +12 elevation of the reactor building and from foar wooden boxes in the radwaste yard. These containers were not labeled as containing radioactive materials. The licensee measured the contact dose rates on these containers as ranging from 5 to 40 mr/hr. The licensee's Senior Chemistry and Radiation Engineer agreed that none of the exceptions described above applied, but stated that the wooden boxes had been labeled at one time, however, being exposed to the weather the labels had faded. Promptly after being identified by the inspector the licensee surveyed the containers and properly labeled them. Failure to have these containers labeled as containing radioactive material is a Violation of 10 CFR 20.203(f)(1) (50-133/84-03-02). I During the exit interview the licensee admitted the Violation and provided the inspector with a draft procedure as part of the corrective action. This procedure, if implemented, would require weekly tours by a supervisor of the Chemistry and Radiation Protection Department to verify that regulatory requirements are being properly implemented, j
- 10. Exit Interview i
At the conclusion of the inspection the inspector met with the individuals denoted on Paragraph 1. The scope and findings of the inspection were presented. The Violations described in Paragraphs 3 and 9 ' were discussed. The licensee's comments on the Violations are described in those Paragraphs. I i
~
t-s
....'.I!ve PACIFIC OAS AND E LE C T.R,I C C O M P.A.NY
!*4 3.-? 2,~
p.7 ,. k HDGwG ;, n acue statu . saa rnancisco. catironnia s4 os . i4:s> >si.42:2 . Twx oto.372-ese7 4
.,. .. .e .,ov 6. . "~C' '
vs.E P.8 5808 1 *
.a.......
September 24, 1984
~ PGandE Letter No.: H8L-84-029 Mr. John B. Martin, Regional Administrator U. S. Nuclear. Regulatory Commission, Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 Re: Docket No. 50-133, OL-DPR-7 Humboldt Bay Power Plant, Unit No. 3 Response to IEIR 50-133/84-03 -- Notice of Violation
Dear Mr. Martin:
NRC Inspection Report 50-133/84-03, dated August 24, 1984, contained one Severity Level IV violation and one Severity Level V violation. PGandE's response to this Notice of Violation is enclosed, f Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope. Sincerel ,
. D. Sch y e Enclosure cc: Service List k
39 p p t o O e t t 7 W' f ,
P PGandE Letter No.: WL-84-029 ENCLOSURE RESPONSE TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT NO. 50-133/84-03 On August 24, 1984 NRC Region V issued one Severity Level IV and one Severity Level V Notice of Violation (" Notice") as part of NRC Inspection Report 50-133/84-03 for Humboldt Bay Power Plant, Unit No. 3. The Notice cited: e An appropriate survey or evaluatfon was not made before pemitting individuals to cut into a line resulting in the internal exposure of - workers.
- e Four boxes located in the radioactive materials storage area, containing licensed radioactive material, were not labeled as required.
In the cover letter to the Notice, concern was
- expressed that the ingestion incident may be symptomatic of a breakdown in the internal radiation exposure control program. An effective program to control internal radiation exposure does exist at Humboldt Bay and continues to be implemented in an effective manner. Prior to the incident, the plant staff review of the design change concluded that this activity did not present a potential for unusual levels of airborne contamination. The plant staff did not document this conclusion.
When airborne contamination did occur, corrective actions and post-incident evaluations were issnediately initiated and conducted. The existing program, together with the initial corrective action, and the additional corrective , action described below, will ensure that an effective program is maintained. i A. APPROPRIATE SURVEY OR EVALUATION WAS NOT MADE i STATEMENT OF VIOLATION "10 CFR 20.201(a) states 'As used in .the regulations in this part,
" survey" means an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioative materials or other sources of radiation under a specific set of conditions. When appropriate, such evaluation includes a physical survey of the location of materials and equipment, and measurements of levels of radiation or concentrations of radioactive material present.' 10 CFR 20.201(b) states in part that 'Each licensee shall make or cause to be made such surveys as are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present'. 10 CFR 20.103 prescribes intake limits of radioactive material by individuals.
i Contrary to this requirement, on December 13,1983, the licensee pemitted four individuals to cut into and open the resin return lines of i the Resin Storage Tank without first making an appropriate survey or
- measurement to evaluate the extent of airborne radioactive material that 1 would be released when the lines were cut. When the lines were cut.
airborne itcensed material was released which resulted in exposure to
,(
j i 2112d/0022K - - .
l_ three individuals. These individuals received an intake equivalent to ( 150, 75, and 50 MPC-hours, respectably (sic). This is a Severity Level IV Violation (Supplement IV)." Explanation and Corrective Steps Taken - As noted in the inspection report, the activity which resulted in the , subject violation was reviewed a.nd approved by the Plant Staff ALARA , Committee and the Nant Staff Review Committee (PSRC) before the job was performed. In their review, Committee members concluded that this i activity did not present a potential for unusual levels of airborne , i contamination. This conclusion was not documented. The potential for airborne contamination was again considered when the Special Work Permit (SWP) was written and issued for the job. The SWP documents this consideration. As a result of this event, Procedure RCP 18 "ALARA Personnel Exposure Control" has been revised to further formalize the ALARA review process and to reflect the existing plant practice of considering both internal and external exposures when performing ALARA reviews. This revision i ensures that internal contamination and potential for airborne radioactivity are reviewed and documented. Corrective Steps Which Will Be Taken I Based on the action described above, PGandE believes that adequate corrective actions have been taken. Therefore, no additional corrective steps are necessary. Date When Full Compliance Will Be Achieved Full compliance has been achieved. B. IMPROPER LABELING OF RADI0 ACTIVE MATERIAL CONTAINERS i STATEMENT OF VIOLATION "10 CFR 20.203(f)(1) states 'Except as provided in paragraph (f)(3) of this section, each container of licensed material shall bear a durable, r clearly visible label identifying the radioactive contents. ' Contrary to this requirement, on July 24,1984, a 55 gallon drum located
- at the +12 foot level of the Reactor Building and four boxes located in
~ the Radioactive Waste Storage Yard contained licensed radioactive
, material and were not labeled as required.
, This is a Severity Level V Violation (Supplement IV)." .
s t i
- 2112d/0022K -_-_-. - - - - -
j . Explanation and Corrective Steps Taken k~ The conditions described in the inspection report correctly depict the violation. The containers were promptly surveyed and labeled as described in the inspection report. ~ A new procedure, RCP 4E, " Supervisory Inspection Tours of Unit No. 3", has been implemented. This procedure requires a supervisor from the Chemistry and Radiation Protection Department to conduct routine inspections of the Controlled Area to ensure and verify continuous implementation of this regulatory requirement. Corrective Steps Which Will Be Taken Based on the actions described above, PGandE believes that adequate corrective actions have been taken. Therefore, no additional corrective steps are necessary. i
- Date When Full Compliance Will Be Achieved Full compliance has been achieved.
( i 1 l k 1 I 2112d/0022K --
- So marg, ' '
f 'o,, UNITED STATES g"7 g NUCLEAR REGULATORY COMMISSION g s - e ftEGION V Q, g 1450 MARIA LANE,sulTE 210
% ,d WALNUT CREEK.CALIFoRNI A 94596 OCT 4 1984 Docket No.'50-133 .
Pacific Gas and Electric Company 77 Beale Street -
) San Francisco, California 94106 Attention: J. D. Shiffer, Vice President Nuclear Power Operations Gentlemen:
Thank you for your letter dated September 24, 1984, informing us of the steps you have taken to correct the items which we brought to your attention in our letter dated August 24, 1984. Based on the telephone conversation on October 2,1984 between Mr. Weeks of your staff, and Mr. Yuhas of our office, we understand that you had recognized the significance of the failure of workers to immediately leave the area when the radiological conditions changed during the inhalation event of December 13, 1983. We further understand that this point had been brought to the attention of your staff, including the maintenance and radiation protection crews. i Your corrective actions will be verified during a future inspection. Your cooperation with us is appreciated. Sincerely, I f6 .
,l ,'
F. A. Wenslawski, Chief t V@ Radiological Safety Branch i l r rO
,$+
_go g
, u e
N ,.
/
r
1 91 , s X ii Docket No. 50-133 M 0 9 19 % Pacific Gas and Electric Company 77 Beale Street, Room 1451 San Francisc^o, California 94106 Attention: Mr. J. D. Shiffer, Vice Pre:;ident Nuclear Power Generation, Licensing Gentlemen: Sulaject : NRC Inniiert ion - limuluililt llay l'ower I'lant Unit .1 This refers to the routine inspection conducted by Mr. Conrad I. Sherman of this office on December 3-7, 1984 of activities authorized by NRC License No. DPR 7, and to the discussion of our findings held by Mr. Sherman with Mr. E. Weeks and other members of your staff at the conclusion of the inspection. Areas examined during this inspection are described in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector. No violations with NRC requirements were identified within the scope of this inspection. In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room. Should you have any questions concerning this inspection, we will be glad to discuss them with you. Sincerely, .
. .d .v . ,
F. A. Wenslawski, Chief Emergency Preparedness and Radiological Protection Bran:h
Enclosure:
Inspection Report No. 50-133/84-04 cc w/ enclosure: Dick Vollmer, NRR P. A. Crane, PG&E S. D. Skidmore, PG&E E. Weeks, PG&E, Humboldt Bay State of CA bec: RSB/ Document Con ~ trol Desk (RIDS); Mr. Martin; Resident Inspector; s pink / green / docket file copies ' RV u?5 Ls SHERMAN7 dot
# k WENSLAWSKI '
'/i/d 8/'I/d
///
qce r;, w n Q
U.S. NUCLEAR REGULATORY COMMISSION a REGION V Report No. 50-133/84-04 Docket No. 50-133 License No. DPR-7 Licensee: Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106 Facility Name: Humboldt Bay Power Plant Unit 3 Inspection at: Eureka, California Inspection conducted: December 3-7, 1984 Inspector: (' h d ,\a [.'k //v/bi C. I. Streeman, Radiatiogpecialist ITate Signed Approved By: O 1 (_(,Lm _ it-tl %-~ G. P. YuTi4s, Chief Ddte ' Signed FacilitiesiRadiological Protection Section Summary: Inspection on December 3-7,1984 (Reprt No. 50_-133/84-04) Areas Inspected: Routine unannounced inspection of a facility in extended shutdown (preparation for SAFESTOR). Inspection of activities associated with the decommissioning process including: processing of liquid radioactive
- waste; effluent releases; solid waste processing; radiation exposure control and ALARA concerns. This inspection involved 32 hours onsite by one regionally based inspector.
Results: Of the areas inspected, no violations or deviations were identified. A s,a
DETAILS
- 1. Persons Contacted
*E. Weeks, Plant Superintendent
*R. Nelson, Power Plant Engineer
*R. Parker, Senior Chemistry and Radiation Protection Engineer R. Lund, Chemistry and Radiation Protection Foreman B. Getty, Supervisor of Operations
. *D. A. Peterson, Quality Control Supervisor G. Ross, Control Operator R. Decker, Radiological Engineer
- Indicates those persons present at the exit interview.
- 2. Followup on Items of Noncompliance (Closed) (50-133/84-03-01) (50-133/84-03-02)
NRC Inspection Report 50-133/84-03 documented inspection findings that i resulted in a Notice of Violation dated August 24, 1984 for one Severity j Level IV and one Severity Level V violation. The inspector verified that ? corrective steps were as stated in the PG&E letter dated September 24, 1984 (HBL-84-029), J. Schuyler to J. Martin and that full compliance was achieved as stated. Violation A resulted from a failure to perform adequate surveys of airborne material. The licensee's response consisted of substantial revision to the ALARA review procedure, RCP-1B, 'Alara Personnel Exposure Control'. In addition, the licensee conducted additional training of radiation . protection personnel on this incident and the lessons to be learned. During tours of the facility, the inspector noted that the respirator equipment cabinet is uncontrolled (unlocked). . This was identified by the inspector to the licensee as a possible contributing factor to the violation. At the exit interview the licensee agreed to examine their program for control of issuance of respirators. This matter is considered closed based on verification of the licensee's response as stated in the Notice of Violation (closed, 50-133/84-03-01). Violation B resulted from failure to label containers containing licensed radioactive material. The licensee's corrective actions which included implementation of a new procedure were verified. This matter is considered closed (closed, 50-133/84-03-02). ( t
2
- 3. Radiation Protection Staff Training and Qualification
- a. Training The licensee system for advising personnel of procedural changes was examined. Training summaries for new or revised procedures were examined for the period May 1984 to date. Selected aspects of the requalification program were examined. In addition the inspector attended a training lecture. The licensee's training and retraining program for radiation protection technicians was found acceptable.
- b. Radiation Protection Staff Program and Personnel Changes The licensee has added two full time contract radiation protection technicians to the plant staff. These individuals were given training during their initial two months at the site. The contractor supplied a certification of qualification for these individuals dated October 15, 1984. This document states that the individuals meet the requirements of ANSI 18.1, 1971 and ANS 3.1, 1978 and 1981 for Health Physics Technicians. This was verified by the inspector based on review of these individuals' resumes'.
In addition to the technicians, the licensee has obtained by contract, the services of a radiological engineer. This individual has approximately 14 years of experience in the nuclear industry. No adverse changes to the training and qualification program for radiation protection personnel were identified.
- c. Audits An audit of training and qualification was included in PG&E Audit 84178P. No audit finding or nonconformance reports were issued.
The area of training appeared to have been adequately reviewed. . Based on review of the licensee's training program and discussion with licensee representatives this area was considered acceptable. No violations or deviations were identified.
- 4. Occupational Exposure Control The inspector's examination of this area included review of audits, dosimetry service, placement of dosimeters, ALARA program, control of radioactive material, surveys and records,
- a. Audits PG&E audit 84306P included the area of ALARA. The auditors examined ALARA committee minutes, initial work review packages and ALARA A review checklists. No negative findings were identified in this area. This audit also examined license conditions related to license provisions such as source inventories, calibration hf monitors, and control of temporary high radiation areas. No o
T 3 negative findings were identified in these areas. An audit by the onsite QA supervisor identified procedural violations of Radiation Control Procedure, RCP-4A involving the logging and control of keys used for control of access to high radiation areas. As a result of this audit Nuclear Plant Problem Report 84-1166 was issued.
- b. Dosimetry The licensee continues to use Radiation Detection Company for their dosimetry vendor. The licensee performs a quarterly comparison of film badge to pocket dosimeter results. The inspector examined unusual exposure events and use of extremity dosimetry. No significant problems were identfied in the area of external -
dosimetry.
- c. AI. ARA' Program The ALARA committee meeting minutes were examined by review of a file maintained by the QA Supervisor. Also examined were the ALARA Review Checklist of Radiation Control Procedure (RCP) 1-B. The licensee establishes project and individual man-rem goals for each job. These are reviewed periodically and tracked. Revisions to procedure RCP-1B described in Section 2.0 of this report have enhanced the ALARA program. Based upon reviews and discussion with personnel, the inspector concluded that the ALARA committee functions in accordance with plant procedures and is generally effective in its functions.
- d. Personnel Exposure Reports The licensee's reports of personnel exposure for 1983, required by 10 CFR 20.407(a)(2) and Section IX.I.1.b of the facility technical specifications were examined.
The maximally exposed individual received less than 2 rem, 75% of those individuals receiving measurable exposure received less than 250 millirem and 96% of all individuals monit ored received less than 500 millirem. Of the total 13.3 man-rem received at the station 39% was received by operating personnel, 31% was received by maintenance personnel and 22% was received by health physics personnel. Dose received in 1983 and 1984 to date compare favorably with prior years based on review of exposures up to September 30, 1984. Year Man Rem / Year Dose / Worker (Rem) 1978 335 1.05 1979 31 0.23 1980 22 0.15 1981 9 0.12 ( 1982 19 0.27 1983 13 0.15 1984 15.4 (partial year) i
4 The increased exposure is a result of increased activity associated with decommissioning. Significant work that produced a large contribution to the collective dose included removal of a hot spot on the scram dump tank (2.9 man-rem) and sampling and surveys of f ra'dioactive waste in the high level vaults (2.3 man-rem). j I
- e. Radioactive Material Control f
The licensee's efforts to control release of The are documented in the Special Radiation Survey (SRS) form. contaminated m I inspector examined SRS's from March 20, 1984 to date. The i majority f were devoted to conditional or unconditional releases of radioac material. Of note was SRS #122 documenting release of oil from an I l i air compressor showing no significant Cesium or Cobalt activityB (less than 10E-8 uCi/cc). f suryeys appear adequate for their intended purpose. Technical Specification VIII-B requires that the liquid and solid l radioactive waste inventories not exceed 10,000 and 50,000 curies f respectively. The licensee has implemented a procedure to perform The inspector reviewed the j this inventory on a semiannual basis. At the time of inspection, ( licensee's inventory dated May 17, 1984. l a second inventory had not yet been conducted in 1984. t l l The requirement to perform this inventory was implemented asThe results of j j Operational Test Procedure (OTP) 7 issued lJune 1984. I specification limits, as described in $6 of this report. f
- f. Surveys and Records and Posting l Records of occupational exposure for 1984 will be examined in a j future inspection (0 pen, 50-133/84-04-01).
Records of radiation surveys performed by radiation protection 20, 1984 * ( monitors ('B' surveys) were examined for the period March to date. High radiation dose rate areas were noted as follows: I Radwaste Concentrator Radwaste Tanks Pipe Tunnel
, Reactor Water Cleanup Room The licensee maintains records of surveys in sequential order and also maintains records of surveys by location for ready reference.
The inspector conducted several In facility tours tothe this review, examine posting following _ practices and verity survey data. J items were noted. A survey of the fuel transfer cask identified a hot spot having a ( non penetrating (surface corrected) dose rate of approx millirem per hour. Other areas around the base of the fuel transfer F in survey records. i 7
e
~
5 cask were properly identified on survey records as having contamination.
~
A survey in the vicinity of the radwaste evaporator indicated ' exposure rates significantly higher at the bottom of the evaporator and on pipes leaving the evaporator at floor level. The inspector noted that these areas were not specifically identified as " hot spots". Survey records and Special Work Permits (SWP) did not reveal an increase in radiation exposure rates in this area. The inspector observed that a pipe elbow leading to the condensate demineralization system was posted with a " hot spot" label. Surveys revealed that the " hot spot" did not exist at the time of the inspection. While the licensee's procedures do not require specific posting of " hot spots", it is considered a good practice to identify locations where radiation dose rates significantly exceed those of the general area. On the other hand, when a source is removed the
" hot spot" labels should also be removed so that the postings remain credible.
A review of survey records indicated that nonpenetrating radiation dose rates are not routinely recorded on survey data sheets. These measurements are required by procedure RCP-7A, Step B.1 and their documentation is required by Step B.5.d of the same procedure. The radiation protection foreman assured the inspector that these surveys were made although no positive evidence was offered. The subject of posting radiation areas, identification of hot spots, performance and documentation of non penetrating radiation surveys was discussed at the exit interview. The inspector also noted that since his last visit, documentation of radiation exposure rates has improved. The licensee has noted that the work effort involved in performing these surveys has resulted in an increase in the l collective radiation dose of the radiation protection monitor group. Based on review of records, observations and discussion with l licensee representatives the area of Occupational Exposure Control t was found acceptable. I l No violations or deviations were identified. l 5. Liquid Waste Processing and Effluent Releases l l The inspector examined the following areas: 1 1 general review of semi-annual report and supporting data l offsite dose calculations l batch release analytical data effluent release monitor strip charts ( l Sources of radioactive waste released during the period January 1, 1984
- to June 31, 1984 were examined to determine if the licensee was making
! efforts to keep releases ALARA. l l I l l
-1 6
I
- a. Audits The inspector examined Quality Control Audit Plan #10 Inspection of Radiation Protection Department, in particular, Control of Radioactive Discharges and Quality Assurance. This Q.C. audit plan was approved by the Plant Manager. This audit will be performed by the licensee at a future date.
I
- b. Procedures and Reports 1
The licensee maintains several procedures for processing and control of cffluent releases. The inspector's review of documentation of radioactive releases for the first half of 1984 indicated that releases are documented in accordance with plant procedures. Semi' Annual Effluent Release Reports required by TS IX.I.3.a and 10 CFR 50.36a(2) for the period January I through December 31, 1983 and January 1 thru June 31, 1984 were examined by the inspector. The 1 licensee has made the following liquid effluent releases. Liquid Maximum Organ
- Period (Excluding Tritium)
Qtr/ Year Dose Commitment Total Curies Tritium (C) (Millirem) 1/83 0.0164 0.01 2/83 0.4 0.0024 0.005 0.01 3/83 0.034 0.012 4/83 0.15 0.046 0.023 1/84 0.19 0.058 0.008 0.20 2/84 0.048 0.006 0.33 annual average 0.03 Curies 0.01 Curies 0.21 Millirem
- annual basis These releases typically result in concentrations in unrestricted areas those below of lessofthan 0.1%BWR's.
operating of the 10 CFR 20 limits. These releases are Releases of this magnitude are considered within the ALARA definitions established by the NRC staff. '
- c. Offsite Dose Calculations Offsite dose calculations are performed by the Senior Chemistry and Radiation Protection Engineer. The inspector examined licensee calculations for the liquid pathway and verified selected calculated doses reported in the semiannual effluent release reports.
- d. Liquid Effluent Monitoring
( Requirements for monitoring liquid effluents are contained in facility technical specification (TS) VII.A.S.d and VIII.A.1 & B.I. The TS do not contain any requirements for calibration of liquid
7 effluent monitors or for quality assurance of radioactive liquid release measurements. The licensee performs electronic calibrations of the liquid effluent monitor in accordance with station procedures. The licensee installed a new liquid effluent radiation monitor supplied by the Nuclear Research Corporation. The licensee installed and operated their monitor without performing an isotopic calibration and without establishing a basis for the alarm setpoint. The licensee representatives have committed to calibrate their monitor prior to January 1, 1985. Failure to calibrate this monitor is not considered a violation as the licensee performs other measurements prior to discharge to measure radioactivity in liquid effluents. The monitor alarm does not~cause an automatic isolation function. No violations or deviations were identified.
- 6. Radioactive Waste Processing The licensee has received proposals from two solidification contractors.
Selection of a vendor is expected shortly. The licensee plans to begin processing and solification of radwaste in preparation for offsite shipment in early 1985. Solid waste stored at the site consists of: 55 gallon drums containing filters and other material; filters and loose material in a bulk container. The licensee estimates approximately 20,000 curies with the following isotopic fractions. Nuclide Fractional % Curies Cobalt-60 12 2600 . Cesium-137 1 280 Iron-55 82 17000
- Nickel-63 3 600 l Strontium-90 0.2 50 Transuranic 0.04 10 In addition, there are about 420 curies of ion exchange resin in storage, consisting primarily of Cobalt-60 and Iron-55. The licensee also has stored approximately 10,000 gallons of liquid stored in the concentrated waste tanks of the following approximate values.
I Isotope Fractional % Curies Cesium-137 20 110 Cesium-134 1 3.5 Cobalt-60 10 50
\ Iron-55 66 360 Nickel-63 2 12 Strontium-90 <1 1 1
8 The waste described above will be processed for offsite shipment. All of the wastes described above have been in storage since February 1983. No violations or deviations were identified.
- 7. Facilities and. Equipment Changes No negative changes in facilities and equipment were identified during the inspection in the area of radiation protection equipment. Positive changes include:
addition of a second channel to the laboratory counting system additional radiation survey instruments have been ordered area radiation monitor channels are being upgraded the liquid effluent radiation monitor has been replaced No violations or deviations were identified.
- 8. Exit Interview The scope and results of the inspection were discussed with the individuals denoted in paragraph one at the conclusion of the inspection on December 7, 1984.
Concerns identified in paragraphs 2, 4.f and 5.d were identified to and discussed with the licensee. The licensee made a commitment to calibrate the liquid effluent channel as described in S 5.d. k 4
4f%ssa n# .
# 'g UNITED STATES
[} g *- g E NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555
- i
* \, ...../ p December 18, 1984 Docket No. 50-133 LS05-94-12-015 Mr. J. D. Shiffer, .Vice President Nuclear Power Generation c/o Nuclear Power Generation, L,icensing Pacific Gas and Electric Company 77 Beale Street, Room 1451 San Francisco, Califnrnia 94106
Dear Mr. Shiffer:
SUBJECT:
DECOMMISSIONING - PUBLIC MEETING Re: Humboldt Bay Power Plant, Unit No. 3 I have enclosed a copy of the transcript of our December 4, 1984 Public Meeting on the environmental review of decomisisoning of Humboldt Bay Power Plant,% Unit No. 3 (Enclosure 1). I have also enclosed a copy of the handout provided by Mr. Erickson at the meeting (Enclosure 2) and the viewgraph charts used by Mr. Ballard and Mr. Swift in their presentations (Enclosures 3 and 4).
, Sincerely, 41 -
! John Zwolinski, Chief l Opera ing Reactors Branch #5 Division of Licensing Enclnsure: As stated CC w/ enclosure: See next page
?'
L 8 n 9 &" " gg
r' Y oya . Mr. J. D. Shiffer December 18, 1984 CC
' 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 Francisec, California 94120 Sacramento, California 95814 Mr.-Eric ". 91'rd C/r191e mor Director Humboldt County Board of Supervisors Energy Facilities Siting Division County Courthouse Energy Resources Conservation & 8?5 Fifth Street Development Commission Eureka, California 95501 1516 - 9th Street-Sacramento, California 95814 Bruce Norton, Esq., 3216 N. Third Street, Suite 202 Gretchen Dumas, Esq. Phoenix, Arizona 85012 Public Utilities Commission Linda J. Brown, Esquire of the State of California
'Donohew, Jones, Brown & Clifford 5066 State Building San Francisco, California 94102 100 Van Ness Avenue, 19 Floor San Francisco, California 94102 Public Affairs Officer Region V Friends of the Earth U.S. Nuclear Regulatory Commission ATTN: ' Andrew Baldwin 1450 Maria Lane 124 Spear Street Walnut Creek, California 94596 San Francisco, California 94105 Office of Intergovernmental
- U.S. Environmental Protection Agency Management Region IX Office '
State of California ATTN: Regional Radiation Representative 1400 10th Street, Room 108 215 Freemont Street Sacramento, California 95814 San Francisco,. California 94105 1 John B. Martin, Regional Administrator Regional Radiation Representative Nuclear Regulatory Commission, Region V Environmental Protection Agency 1450 Maria Lane, Suite 210 ' Region IX Walnut Creek, California 94596 215 Fremont Street Michael R. Sherwood, Esq. San Francisco, California 94105 Sierra Club Legal Defense Fund, Inc.
.. 2044 Fillmore Street Office of Intergovernmental Managemen State of California San Francisco, California 94115 1400 10th Street, Room 108 l
Dr. Perry Amiroto Sacramento, CA 95814 i
}$nartr.entofConservation
; vision of Miros A Geoiogy 141C 9th Straet. P.ocm 1341 L Sacrcr.: ento, Califernia 95814 L
Enclosure 1 UNnED STAiES T R FCUT A__T_. O.R_Y_. COW.mf_C SION
.. . TUN. .wF A. ._R_.
. . v -
IN THE M.A A irk OF: DOGGT NO: 50-133 ENVIRONMENTAL REVIEW OF
. DECOMMISSIONING HUMllOLDT BAY NUCLEAR POWER PLANT PUELIC MEETING .
LOCATION: ~ EUREKA, CALIFORNIA PAGES: 1 _ g9 i DATE: TUESDAY, DECEMBER 4, 1984 l l 1 . l
. CE-Fsosn.u REPORTERS, b:c.
l 7 C(5:b:1Repo-te s i O 4 '-1 Ner.h Czeitel 5::eet
- d .l:.n, 'D.C. :3001 (202)347-3700
m
-8 4 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3
4 ENVIRONMENTAL REVIEW 5 OF DECOMMISSIONING HUMBOLDT BAY 6' NUCLEAR POWER PLANT 7 , 8 PUBLIC MEETING 9 10 Humboldt County Board of Supervisors Chambers ! 11 825 Fifth Street l Eureka, California 12 Tuesday, December 4, 1984 13 The Commission met, pursuant to notice, at ic. 14 7:00 p.m.
, 15 -
! FrFORE: 16 ERVIN C. RENNER, Moderator p 17 Member, Humboldt County Board of Supervisors l 18 JERRY J. SWIFT, Radiological Assessment Eranch, l- Nuclear Regulatory Commission i 19 j RONALD BALLARD, Environmental and Hydrologic , 20 Engineering Branch, Branch Chief, Nuclear l Regulatory Commission ! 21 l PETER ERICKSON, Humboldt Bay Nuclear Power l 21 Plant, Project Manager, Nuclear Regulatory
. Commission 23
., 24 25 l REPORTED BY: PATRICIA RENAIT i
I
F 2 1 INDEX 2 Opening Remarks by Mr. Renner 3 3 Introductory Remarks by Mr. Erickson 5 4 Environmental Review Process by Mr. Ballard 6 5 Radiological Review Process by Mr. Swift 12 6 Public Speakers 7 David Miller 14 8 Liz Murguia 15 9 Steve Lieker 19 10 Wesley Chesbro 24 11 Victor Green 28 12 Matthew Horns 30 13 Carl Zichella 31 14 Larry Goldberg 35 15 Debby Harrison 40 16 C. J. Speciale 40 i 17 LeAnna Carson-Hansen 42 18 Scott Fielder 45 19 Fred Cranston 48 20 Jared Rossman 49 21 Stephen Kennedy 53
~
22 James Adams 54 23 Mark Mullins 56 24 Bonnie Blackberry 57 25 Agnes Mansfield 58 k
7_ 2A 1 (Public Speakers, continued) 2 Arlo Hagler 60
- 3 Ron Glick 61 4 Iian Isotope 64 5 Sunshine Mansfield 65 6 Lewis Hedrick 65 7 Peter Folks 66 8 Barbara Arnold 68 9 Greg Wellish 69 10 .Bea Stanley 74 11 Dr. George Jutila 78 12 Peter Kayes 82 13 Kupiri Waterfall 85 86
.'( 14 Holly Sweet 15 Andy Colonna 87 l t
16 Tom O'Neil 94 f I 17 Billie Bergmann 97 18 Summary Remarks by Mr. Erickson 98 j 19 Closing Remarks by Mr. Renner 99 l l 20 // 21 i b 2I 23 24 25
3 I PEQ(({EIEQE 2 MR. RENNER: This public meeting will come r 3 to order. There are some housekeeping matters that I.will 4 insist on before we start. 5 My name is Erv Renner. I am a member of 6 the Board of Supervisors. I have been asked to chair this 7 public meeting. 8 For anyone that wishes to testify before 9 the three gentlemen of the Nuclear Regulatory Commission 10 there are sign-up sheets in the back. If you wish to testify 11 please sign up so that we can recognize you when your turn 12 comes. 13 There are some elected officials here this evening of whom we have been notified. Are there any other (;. 14 15 elected officials here? I will recognize those first, 16 and then we will go to the list. 17 I would ask that everyone try to confine 18 their comments to five minutes or less. If you exceed 19 the five-minute deadline I will ask you to conclude in 20 your next sentence. At the end of the evening, if you 21 have some additional remarks to make that you were not 22 able to make at that particular time from your prepared-23 remarks, you can do so then. t. 24 Also, I understand that we will not have 25 an exchange of dialogue with the members of the Nuclear
v oc 4 4 1 Regulatory Commission responding to questions that may 2 be asked. If you have questions, I understand that Mr. 3 Randall has agreed that he would be willing to stay after (} 4 the meeting and discuss some questions that you may have 5 with him, if that is agreeable. I understood that he agreed 6 to do that. 7 The purpose of this public meeting is to 8 establish the scope of the Nuclear Regulatory Commission's 9 environmental review of the decommissioning of the Humboldt 10 Bay nuclear power plant. 11 The application for decommissioning was 12 submitted by Pacific Gas and Electric Company on July 30, 13 1984.
"c 14 The meeting is open to members of the public 15 in order to provide an opportunity for them to express 16 views.regarding environmental concerns to the Nuclear 17 Regulatory Commission staff members who are present this 18 evening.
4 19 Comments and views on the decommissioning 20 of the nuclear plant may also be sent to the Nuclear 21 Regulatory Commission's Project Manager, Mr. Peter Erickson, 12 Washington, D. C., 20555. These comments may be sent to 23 Mr. Erickson after this meeting this evening. 24 A transcript of this meeting will be made 25 available through the Nuclear Regulatory Commission's
5 1 public document room in Washington, D. C. and at the Eureka 2 Humboldt County Library. I assume that will be probably 3 in the next few weeks. 4 Ladies and gentlemen, I believe there are 5 some additional seats. You may also line up along the 6 back of the room, but please keep the aisles clear. 7 The introductory remarks this evening will 8 be made by Mr. Peter Erickson, the Nuclear Regulatory 9 Commission's Project Manager. 10 Mr. Erickson's remarks will be followed by 11 the environmental review process by Mr. Ronald Ballard, 12 who is the Branch Chief, Environmental and Hydrologic 13 Engineering Branch of the Nuclear Regulatory Commission. 14 There will be some view graphs shown in 15 conjunction with those remarks. The television folks will 16 be asked to please dim some of the lights so that the 1 17 audience can view the screen. 18 Those remarks, then, will be followed by 19 .the radiological review process by Mr. Jerry Swift of the 20 Nuclear Regulatory Commission's Radiological Assessment 21 Branch. 22 The evening will begin now with Mr. Erickson. 25 Mr. Erickson. 24 MR. ERICKSON: First of-all, thank you, Mr. 25 Renner, for your participation in this meeting and for your
6 1 serving as the moderator. I would also wish to thank you 2 for the use of your facility here. This has been a great 3 convenience to us and, I am sure, to the public who comes 4 here to talk tc us about the decommissioning of the plant. 5 To the members of the public here, this is 6 your meeting. This is your opportunity to express your 7 views about the decommissioning of the Humboldt Bay plant. 3 You may sign at the sign-up sheet in the 9 corner, if you have not already done so, for speaking. 10 I have provided some hand-outs. And I think, perhaps, 11 we ran out, although I brought about a hundred of them, 12 but those of you who have them, the hand-outs have several 13 different items: kJ 14 (1) The agenda of our meeting; 15 (2) There is a copy of our Notice of Public 16 Meeting on this meeting that was published in the local i 17 paper. And it also includes an address in there for your i 13 sending in additional comments; my address and also my 19 phone number if you wish to call me. Comments will be 20 received after this meeting; 21 (3) An executive summary describing Pacific 22 Gas and Electric's summary of their environmental report 23 for the decommissioning of the plant. In that summary 24 PG&E describes those issues which they think are important 25 to the environment; and finally
7 1 (4) A list of reactors, and we will show 2 this on the screen, that have been decommissioned in a 3 manner similar to-that being proposed by the Humboldt Bay 4 plant. 5 (Slide) - 6 First of all, at the top we have the VBWR, 7 which is a 50 megawatt reactor that was shut down in 1963. 8 It was issued a possession-only license in 1965, so it 9 has been in a safe-storage mode since then. That is located -- 10 it does not show on the screen, but it does show in the 11 hand-out -- in Alameda County, California. 12 FERMI 1, a 200 megawatt plant, a fast-reader 13 reactor shut down in 1971, was issued a possession-only (, 14 license in 1973; that is a safe-storage mode. It is in 15 Monroe County, Michigan. 16 Third on the list is INDIAN POINT, Unit 1, 17 a 615 megawatt pressurized water reactor which was shut 18 down in October of 1974. They submitted their application 19 for decommissioning using the safe-storage followed by , 20 dismantling when their second unit is also shut down. 21 That is in Westchester County, New York. 22 PEACH BOTTOM 1 is a gas code reactor, 115 23 megawatts thermal, that was shut down in 1974 and issued L.. 24 a possession-only license in 1975 in York County, 25 Pennsylvania.
8 1 Then we list Humboldt Bay, Unit 3, a 220 2 megawatt thermal reactor which was shut down in 1976. 3 Their application for a possession-only license and safe 4 storage is now under consideration. - 5 The Nuclear Ship SAVANNAH, an 80 megawatt 6 pressurized water reactor, was shut down in 1970 and was 7 put in safe-storage in 1981. It is presently located in 8 Charleston, South Carolina and is being used as a museum 9 in the Patriot's Point Development Authority's museum at to Charleston, South Carolina. 11 The ship still has radioactivity in the 12 reactor vessel internal to the ship that is protected by 13 shielding, but is used now as a museum.
~ 14 Again, this is your meeting. This is your 15 opportunity to tell us what you think should be in the 16 environmental statement and what we should consider in 17 our review of the Humboldt Bay plant decommissioning.
18 I would now like to introduce Mr. Ronald 19 Ballard, who is Chief of our Environmental and Hydrologic i l 20 Engineering Branch. He will discuss the environmental 21 review process. Mr. Ballard. 22 MR..BALLARD: Thank you. I will take a few l l 23 minutes now to briefly describe the NRC's environmental
- 24 review process, and how these procedures are integrated 1
25 into the agency's decision-making process. I
r-9 l 1 I am going to put up a view graph here that 2 .you will be able to follow in the structure of my very 3 brief discussion here. 4 (Slide) 5 I am afraid our screen is not quite full 6 enough, but we will do the best we can here. As you will 7 see, the NRC's Environmental Protection Regulations are 8 spelled out in Chapter 10 of the Code of Federal Regulations. 9 The environmental portion of those regulations 10 is part 51. Copies of these regulations are, of course, 11 available through the MRC's Public Document Rcom. 12 First of all, the environmental review process 13 is usually initiated by an applicant or a licensee in the
- s. 14 form of an application.
15 The criteria for the type of reviest that 16 the NRC will conduct is spelled out in part 51. There 17 are a number of categories of environmental reviews. Under 18 the present regulations any application for a decommissioninc 19 activity requires a formal environmental impact statement. 20 That is the process we are now initiating. k 21 After we receive an application the agency b 22 issues a notice.to the Federal Register. They usually 23 follow up further with press releases to the public.
'- 24 After we have noticed this, the agency then 25 establishes a Project Manager, Mr. Erickson, whom you have
r_ 10 1 been introduced to here this evening, and a Technical Review 2 Team is established. i~ 3 This review team is made up of a number of 4 experts from a number of different disciplines. Typically 5 we include on a review team econimists, health physicists, 6 environmental engineers, biologists, and social scientists. , 7 Now, the depth of review, under NEPA (phonetic) , 8 is fairly well established by what we determine to be the 9 significance of the impact. And in the case of this 10 decommissioning part of the process will involve your 11 comments.
'12- The Technical Review Team will generally 13 establish contact with the appropriate state and local k/ 14 agencies in the area. We have routine contacts with the 15 federal agencies also; Department of the Interior and EPA, 16 primarily.
17 When we start the environmental statement 18 process the regulations that I mentioned to you generally 19 spell out the requirements. They spell out requirements 20 not only for the licensee's or the applicant's environmental 21 report, but also spell out, in general, the procedural 22 requirements that the staff will follow. 13 Part of that, and early on in that review, 24 is the scoping process whereby the staff reviews the 25 applicant's environmental reports, and we seek comments
r 11 1 from the public. We are at that stage now, of the public 2 meeting. ( 3 The staff will follow-up, if necessary, with 4 site visits and even go so far, if there are technical 5 problems that we may need outside consulting help on, we 6 can go that far. We do not foresee that at this stage. 7 Then the staff prepares a draft environmental 8 impact statement which will be circulated to the public 9 and Noticed in the Federal Register. This draft statement, 10 then, provides at that time we provide a public comment 11 period where formal written comments are received by the 12 agency. 13 This period of time is typically from 45 E 14 to 60 days. I think this will be at least a 45-day comment 15 period. 16 After we receive these comments then the 17 Technical Review Team prepares a final environmental 18 statement. This statement then incorporates the comments 19 that are received. It indicates just how the staff has 20 handled the comments and, where indicated, the statement 21 would be revised to reflect any new information that results 22 from the comments. 23 The final step in this stage is a record 24 of decision. A designated NRC official will review the 25 environmental statement. It will also take into account
F. 12 1 the staff's safety evaluation report, which is a separate 2 process. (' 3 These two documents, as well as any other 4 pertinent information, will be taken into account. Then 5 the official will issue a license amendment with any 6 appropriate conditions that are applied to that license. 7 These condition are not, at this stage, known 8 for the Humboldt Bay activity. It could include monitoring, 9 but whatever the environmental reviews indicate, and the 10 safety reviews, why the ccnditions will be applied to the 11 license. 12 Now I would like to have Mr. Swift give you 13 a brief presentation. He is a Health Physicist. He is
- 1. - 14 on'this review team', and he will briefly describe how we 15 go about the radiological portions of the review.
16 MR. SWIFT: In the environmental part of 17 our review we are reviewing this proposed process from 18 two sides; the environmental and the safety evaluations. . 19 I am just here as the environmental side. 20 We are looking at the period of storage, 21 called SAFSTOR, and the decontamination and decommissioning 12 of the plant as to -- pardon? 15 MR. RENNER: The public is having trouble
. 24 hearing you, Mr. Swift. Perhaps if you could move just 25 a little closer to your microphone?
i 13 1 MR. SWIFT: I will move closer, certainly. 2 We will be reviewing both the SAFSTOR, the storage period 3 and-the decontamination and decommissioning of the plant ({ 4 rather as separate pieces. And in both of those we will 5 be looking at the impact of both routine operation and 6 the possible impacts of accidents. 7 We will also be looking at the impact on 8 the environment directly, and also at the occupational 9 exposure of the plant workers. 10 In addition, we will be reviewing the licensee' s 11 proposed monitoring program to see that it is satisfactory. 12 And when we have settled on a satisfactory program, that 13 will be included in their technical specifications as a
,m-
! \ s- 14 part of their license.
.15 (Slide) _
16 This view graph shows, in a simple form, 17 some of the environmental pathways for radiation exposure. l' 18 And we generally look at all of those pathways, at least l 19 to the extent that they are applicable. 20 For instance, here on the lower-left it shows 21 irrigation. There probably is not any irrigation pathway 22 in the neighborhood here, but I believe all the others i 23 are applicable.
'- 24- I believe that covers what I have to say now.
25 Thank you. i i l t
14 1 MR. RENNER: Thank you. We will begin now 2 -with the public testimony. Please confine your remarks 3 .to the purpose of this meeting, which is to establish the 4 scope of the Nuclear Regulatory Commission's environmental 5 review of the decommissioning of the Humboldt Bay Nuclear 6 Power Plant. 7 I recognize a number of representatives of 8 our elected officials as well as some elecced officials 9 in the audience, no the Chair will exercise the prerogative 10 of calling upon those people first. 11 I will now recognize the representative of 12 Congressman Bosco's office, Mr. David Miller. 13 Please try to keep theaisle open so the folks w.c 14 can come up and approach the podium. 15 MR. MILLER: Thank you, Mr. Chairman. I 16 will keep my comments very brief. I am here as the 17 representative of Congressman Doug Bosco to welcome the 18 NRC and to wish them the very best in their deliberations j 19 today. 20 I would like to extend my personal thanks 21 to Pete Erickson, who has been very helpful in keeping 22 our office in communication with the NRC and their l 23 deliberations. 24 I think, as you can all see by the public 25 turn out here tonight, there is a great deal of local and
15 1 regional interest in this topic. 2 I would like to offer to the NRC and to anyone 3 here in the audience our offices and whatever help we can 4 provide towards a safe, orderly and expeditious handling 5 of this matter. Thank you. 6 MR. RENNER: Thank you, Mr. Miller. 7 I saw in the audience a representative of 8 our State Senator Barry Keene's office, Ms. Liz Murguia. 9 MS. MURGUIA: Thank you, Erv. I have copies 10 of Senator Keene's testimony. Should I present that to 11 the Committee? 12 MR. RENNER: Surely. If you wish to, present 13 the testimony first and then you can give a copy to the C 14 reporter. 15 MS. MURGUIA: Senator Keene could not be 16 here this evening. He asked me to present his testimony. 17 First, I w'ould like to thank the Nuclear Regulatory 18 Commission for allowing the North Coast citizens this l 19 opportunity to express their views conce,rning environmental 20 'i ssues related to the decommissioning of the Humboldt Bay i 21 Nuclear Power Plant. 22 I am confident this meetinig will help the , 23 NRC identify significant environmental issues which should 24 be fully analyzed in the draft and final environmental 25 impact statements.
16 As you know, Pacific Gas and Electric Company 1 2 filed an environmental. report that recommends and focuses 3 its analysis on the so-called SAFSTOR decommissioning method, 4 The spent fuel would remain in the facility's 5 spent fuel storage pool until a federal repository is 6 available to receive commercial fuel. 7 The SAFSTOR decommissioning plan may be one 8 of the better alternatives for decommissioning, but we, 9 as a community and a nation, cannot ignore the possibility 10 that other methods may provide a safer decommissioning 11 alternative. 12 Accordingly, I strongly urge the Nuclear 13 Regulatory Commission to consider and assess the environmenttl l c. - 14 impacts of all reasonable decommissioning options when 15 it prepares its own environmental impact statement. 16 For example, the EIS should' include full-17 scale environmental analyses of the following alternatives: 18 (1) Immediate or near-term dismantling of 19 the facility, along with interim or permanent storage in 20 pools or dry casks at an installation away from the Humboldt 11 Bay site; 12 ( 2.) Temporary entombment in a protective 13 seal; and 24 (3) Upgrading the onsite spent fuel storage 25 facility to prevent leakage and to withstand major earthquakes.
17 1 The Humboldt Bay facility is one of the first 2 nurclear power plants of its size, and with its length 3 of service,to be decommissioned. (' 4 Without previous experience, we have many 5 unanswered questions about the closing's dangers to the 6 public's health and safety, as well as the dangers to our 7 environment. 8 It is crucial that the NRC explore all these 9 questions in its environmental analysis of Humboldt Bay. 10 Other issues involved in Humboldt Bay's decommissioning 11 include: 12 SEISMIC RISKS: As you know, the PG&E facility 13 is located only four miles from the city of Eureka and k- 14 stands only.a few hundred feet from Humboldt Bay, placing 15 both North Coast citizens and natural resources at great 16 risk should the SAFSTOR program prove to be unsafe. 17 Three geologic faults occur near the facility, 18 and concern over the plant's ability to withstand a major 19 earthquake forced its closure. 20 The NRC EIS should provide a full analysis 21 of the possibility of a major seismic event occurring during 12 the next thirty years. 23 The associated public health, safety and (- 24 environmental risks related to destruction or damage by 25 an earthquake also require consideration.
18 r 1 LEAKAGE: With the storage of spent nuclear i 2 . fuel rods there is a possibility that future leakage from
'~' 3 the fuel rods storage pool may contaminate the ground water 4 and/or the adjacent Humboldt Bay.
5 The addition of stainless steel liners has 6 not prevented continued leakage from the pool. We need 7 to explore further safeguards against leakage and assess 8 tt'e impacts on those leaks. 9 WORKER EXPOSURE RISKS: I share PG&E's concern 10 for the workers who will eventually dismantle the Humboldt 11 Bay facility, but we must also consider the cumulative 12 effects of thirty years of radiation exposure to SAFSTOR 13 workers. ?,
'-(J 14 In considering these workers' safety, I sugges3 15 your EIS include the possibilities of both decay and 16 activation, which is the increasing levels of radiation 17 in' steel, concrete and other parts of the plant.
18 MARINE ENVIRONMENT: As a Chairman of the 19 Legislature's Joint Committee on Fisheries and Acquaculture, 20 'and a representative of a district that depends heavily 21 on fisheries for jobs, I have a particular concern with 22 the risk posed by radiation in the marine environment. 23 Your EIS needs to consider the potential 24 effects of any release of radiation into Humboldt Bay or 25 the Pacific Ocean, keeping in mind the fact that radiation
\
F' . . 19 I can bioaccumulate in the human food chain on which the 2 North Coast economy hangs. g_ 3 These effects include the potential cumulative ( 4 effects of all the various of radiation in the sea, 5 including: 6 (1) Natural background radiation; 7 (2) Radioactive fallout from past and 8 potential future atmospheric nuclear testing; 9 (3) Contamination from past and potential 10 future ocean dumping of radioactive wastes; and 11 (4) Accidental losses of other radioactive 12 materials. 13 In conclusion, all of these issues will have (h; 14 impacts on the work force, the general public and our 15 environment. It is crucial that you thoroughly consider 16 these issues and how the various decommissioning alternatives 17 may effect them. 18 Your _avestigation and analysis will lay 19 the groundwork for many future decommissionings. We cannot 20 proceed with such major projects as nuclear power plant 21 decommissionings without answers to the serious questions 12 posed by our community and nation. 23 Thank you. ( 24 (Applause.) 25 MR. RENNER: Thank you, Ms. Murguia.
r' 20 1 I will ask that you please refrain from 2 . applauding; otherwise, we are going to be here until 2:00 3 o' clock in the morning. We appreciate the comments that 4 are being made by everyone that is going to comment here 5 tonight, but please hold your applause. If you wish to 6 clap, clap at the end. 7 I would ask now that the representative from 8 Assemblyman Dan Houser's office, Mr. Steve Lieker, present 9 his testimony. 10 MR. LIEKER: Thank you, Supervisor Renner. 11 Members of the Commission's Staff, it is 12 a pleasure to have you here. My name is Steve Lieker. 13 I am the Field Representative to Assemblyman Dan Houser. (. y;r 14 Dan Houseralso is in session, and is in Sacramento; however, 15 he does have a statement. I do not have a final copy of 16 it, but I will pass this on to you at a later date. 17 Thank you for the opportunity to present 18 a few of my thoughts this evening in regard to the 19 decommissioning proposal to SAFSTOR the Humboldt Bay Nuclear 20 ' Power Plant. 21 I am pleased that you have decided to call for i 22 the preparation of a full-blown environmental impact ' 23 statement. Back in March of this year the Redwood Alliance ( 24 and other highly interested groups of individuals, including 25 myself, asked that an EIS be prepared.
F. . .. . . ,..s.__-. . ....... . i j 21 l 1 The Nuclear Regulatory Commission has complied l 2 with that request. This evening I am hopeful that you e- 3 will be guided as to the content of that document by the
\.-
4 testimony of those groups and individuals that have been i 5 in contact with me and, I am sure, with you. 6 Since much of their testimony will address 7 the technical details of the decommissioning. process I 8 will confine my testimony to a few of the issues which 9 are of utntost concern to me, because of the affect they 10 may have on my constituents in the North Coast. 11 Some major areas which need to be addressed 12 in the EIS include: 13 (1) Removal of spent fuel rods from a (c. 14 leaking storage facility; 15 (2) Potential for environmental damage 16 resulting from an earthquake in this geologically active 17 area; and 18 (3) The degree of security that will be 19 in place to ensure that the radioactive elements will be 20 secure during the proposed thirty year SAFSTOR peri?d, 21 should the radioactive elements be left at the current 22 facility. , 13 The first two issues raised above are
'( 24 inextricably linked. This is earthquake country.
~
The 15 highly-radioactive material stored at the plant presents,
r . . . . . . . .. . . . . . _ . . _ - - . . _ . - - . . . . _ . . 22 1 therefore, a great danger to the residents of this area. 2 I have asked in the past if any thought has 3 been given to relocating this radioactive material to another 4 more compatible site. 5 Such a site might be at Diablo Canyon where 6 such storage facilities for spent waste will already be 7 in. place. 8 If offsite storage is selected, then barge 9 transportation of nuclear waste needs to be examined by 10 the EIS; that is, barge transportation needs to weighed 11 and compared to land transportation of such wastes over 12 Humboldt County's occasionally closed and sometimes 13 chronically disrepaired road system. l I l - (c- 14 Beyond the potential for storage of spent 15 fuel at Diablo, there are other facilities that should 16 be researched such as those facilities operated by the 17 Department ~of Energy and Defense. 18 These facilities are currently being utilized 19 for the disposal of waste being generated through their 20 process of decommissioning of other nuclear po-ar plants. 21 Due to the fact that a leak has been detected 12 in the spent fuel storage facility at the Humboldt plant 13 the probability and consequences of a catastrophe caused 24 by an earthquake need to be determined. 25 The potential for loss of human life under
F
)
i 1 23 i 1 current storage arrangements are intolerably high. I am I 1 2 not only concerned with the severe health risks that thirty 3 year's containment poses to the Humboldt area, but also 4 to the very real threat of terrorist activity. 5 As I have already mentioned, serious thought 6 should be given to storing this waste -- alluring to 7 terrorists if stored on the isolated North Coast -- at 8 a facility where security measures are already in force. 9 If this is impossible to do, I would be very 10 interested on behalf of my constituents to know just what 11 security measures will be in force if these radioactive 12 materials are to remain on Humboldt Bay for thirty years. 13 Thank you for listening to me and other (, 14' interested members of the general public regarding this 15 issue. I am certainly hopeful that the environmental 16 review process will be fully thorough and open to the 17 concer'ned public. 15 . If I can be of any assistance to you during 19 the process in which you are currently embarking do not 20 hesitate to contact me. 21 This is signed, " Sincerely, Dan Houser." 22 I again thank you for being here and listening to the 25 interested members of the community.
;) g-24 MR. RENNER: Thank you, Mr. Lieker.
25 MR. LIEKER: Thank you.
24 1- MR. RENNER: Supervisor Wesley Chesbro. 2 SUPERVISOR CHESBRO: Good evening. First 3 of all, I would like to thank you very much for coming 4 to the North Coast to allow the people who live here and 5- whose lives are affected by the Humboldt Bay Nuclear' Power 6 Plant to tell you how we feel about this issue. 7 I also would like to thank the Nuclear S Regulatory Commission for agreeing to do an environmental 9 impact statement, which I, along with many North Coast 10 residents and elected representatives, requested. 11 I think it was a major step forward in terms 12 of our opportunity to participate in the decision-making 13 process. f, 14 The people of Humboldt County were not asked 15 whether or not they wanted the Humboldt Bay Nuclear Power 16 Plant here, nor were we informed of what the potential 17 risks and health and environmental impacts of the location 18 of such a plant here would be. 19 From the day that the Humboldt plant was 20 conceived the people of this area have been guinea pigs 21 in the experiment of nuclear power. Now that that 22 experiment has failed, we are'about to become guinea pigs 23 again. This time the experiment is called " decommissioning." 14 We can only hope that the experiment of 25 decommissioning is more successful than that of nuclear e w- -
--g- egspp- g-- -
. - - ----%--r-------M
1 I 25 I power as a safe or economical energy supply for this county 2 or for the nation as a whole because, if this experiment 3 fails, the price will be paid right here in Humboldt County [ 4 in the form of pollution and the endangerment of our health 5 and our environment. 6 If the history of this plant was a forewarning 7 of what is to come for the rest of the nuclear power industry , 8 then what happens here with decommissioning will also be 9 of great importance to the entire country, particularly 10 to utility companies, utility users and to the public in 11 general with regards to power plants that are now operating 12 or are just starting up, such as Diablo Canyon, which 13 represents a plant with thirty times the capacity of the
. 14 Humboldt Bay Nucler Power Plant, so although this issue l
15 may seem small in terms of its specific significance to I 16 the entire country, a precedent is being' set here about 17 how it will be done that is of great significance. 18 The option that I would recommend for 19 decommissioning involves two steps: 20 First of r te immediate removal of the 21 spent fuel from the site . from Humboldt County to a 22 site that is better suited and specifically designed for 23 safe storage of such dangerous materials; and
- 24 Secondly, the dismantlement and removal of 25 the Humboldt Bay Plant at the earliest feasible date.
t 1 26 1 This decommissioning option should be given 2 equal study and consideration in the Environmental Impact (". . 3 Statement to the option of storing the plant at this site 4 for thirty years, or the SAFSTOR option, as PG&E has so 5 euphemistically labeled it. 6 I favor this option for the same reason that ~ 7 the plant was shut down in the first place; the plant sits 8 virtually on top of two active earthquake faults. 9 The NRC has established that the plant is 10 not adequately designed to safely withstand the effects 11 of the maximum possible earthquake at this site, while 12 operating. , 13 It has not, however, been clearly established
- 14 whether or not the spent fuel storage facility can, likewise, 15 stand or not stand such seismic effects.
16 The rupture of the spent fuel storage facility 17 could result in human and environmental radioactive 18 contamination. Under PG&E's proposal, the plant would 19 bear such a risk for thirty years, which is more than twice 4 20 'the operating life of thirteen years that the plant 21 experienced. 22 The other major concern that I have for leaving 25 the plant in its current status for thirty years is what
. 24 has already been alluded to here by several previous
; 25 speakers, and that is the existing leak in the spent fuel 1
- ,m .. ,,.-ee,---e-.,
_ . -,,.---,,-n-- --,,.-w. - -n. - , --s , n- - . , - - .,-g. ,. -. , , , - - - . - -
7_ - _ _
~
27 m I storage facility, the impacts of which are not known. 2 What are the impacts of these poisons on 3 Humboldt Bay; on ground water; on fish, shell fish; and 4 last but not least, on human beings who live on Humboldt 5 Bay? What would be the effect of allowing this leak to 6 continue for thirty years? 7 In summary, the risks from potential 8 earthquakes on adjacent faults during the thirty-year storage 9 period must be seriously considered. 10 The extent of the existing radioactive 11 pollution leaking from the spent storage pool; the impacts 12 of thirty years of such leakage as well as the possible 13 ennvironmental and health impacts of exposure from a rupture
~l 14 to that pool due to an earthquake must all be carefully 15 analyzed.
16 I feel very strongly that if a thorough 17 analysis of the options is includei in this Environmental 18 Impact Statement that the alternative of immediate removal 19 of the spent fuel and subsequent dismantlement as soon 20 as feasibly possible will emerge as the safest and most 21 econonical approach to decommissioning. 22 Being guinea pigs for thirty more years, 23 as PG&E has proposed, is clearly the least desirable 24 alternative to the people in Humboldt County and only puts 25 off until tomorrow what should, for public health, safety
f 28 1 and environmental reasons be done today. 2 Again, I believe a thorough analysis of the 3 facts in this Environmental Impact Statement will bear l 4 this out. 5 Thank you again for coming to Humboldt County 6 and giving myself and the other elected officials as well 7 as my consituents and the other residents of Humboldt County 8 the opportunity to address you on this very important issue. 9 MR. RENNER: Thank you, Supervisor Chesbro. 10 (Applause.) 11 MR. RENNER: Please hold your applause. 12 City Councilman Victor Green. 13 COUNCILMAN GREEN: Thank you, Erv. I have 14 a few copies here that I can hand out. (So doing.) 15 I would also like to thank the Committee 16 for ccming here today. I think that is great, for you 17 to come to Humboldt County and to give the people of this 18 county an opportunity for you to listen to us. 19 First of all I would like to say that I am 20 a member of the Arcata City Council. I am here representing 21 the City Council tonight. 12 I was elected in 1980. Also, when I was 23 elected in 1980, propositions were being passed by a 24 two-to-one margin calling for the permanent closure of 25 the Humboldt Bay Nuclear Power Plant and to look for other
F 29 I alternatives. 2 That was very significant in Arcata. There 3 was a big election, and I think it showed that the people
~.
4 wanted Humboldt Bay Nuclear Power Plant shut down at that 5 time. And they continue to want that done today. That 6 is why I am here to speak to you. 7 I will just read the letter before you: 3 "The City of Arcata wishes to express its 9 concern regarding the decommissioning of to the Humboldt Bay Nuclear Power Plant. Aracata 11 is located approximately nine miles north 12 of the power plant where nuclear fuel is 13 being stored. We would like to see this
-N- 14 fuel storage facility removed from the Humboldt 15 Bay Nuclear Power Plant and Humboldt County 16 at the socnest possible date. We feel for 17 the health and safety of Aracata residents 18 this storage facility sits on an earthquake 19 fault. In the event of a major earthquake 20 the people of Humboldt County and our 21 environment is at stake. This site should 22 no.t be used as a cemetery for nuclear wast'e r 23 which has the ability to destroy our lives.
l 24 Sincerely, Victor Green." 25 Do you have any questions, any of you? s
30 1 (Pause.) 2 MR. RENNER: Thank you, Councilman Green. 3 COUNCILMAN GREEN: Thank you, very much. 4 MR. RENNER: I believe that completes the 5 roster of elected officials. Are there any more elected 6 officials in the audience that I have not been able to 7 see? 8 (Pause.) 9 All right. We will begin with the sign-up 10 sheet. Mr. Matthew Horns. 11 MR. HORNS: I want to thank you for letting 12 me talk. I just have some brief comments. One thing is 13 the disposal of high-level radioactive waste is of great 14 concern, one of the major concerns with environmental 15 concerns of the nuclear industry. 16 And public pressure has only recently mandated 17 a major public effort and private research effort to solve 18 the problems of high-level waste disposal. 19 And I hope that whatever policy is implemented 20 here that the NRC does not allow the thirty-year SAFSTOR 21 method,or whatever method,to allow that as an excuse to 12 delay research on high-level waste disposal. Okay. s 23 And also, my other concern is new information 24 is always coming up. And I hope that whatever decisions 25 are made that any policies that are adopted contain language m_________ _ _ _ _ _ _ _ _ __ _ _ _ _ _ . i o e i
t t 31 I that call for a prompt response and revision under public 2 . review when any new information or technology becomes 3 available. 4 Thank you. 5 MR. RENNER: Thank you, Mr. Horns. 6 Mr. Carl Zichella. 7 MR. ZICHELLA: I would like to take this 8 op'portunity to thank the members of the NRC for coming 9 out here today; also, to thank you, Mr. Renner, for agreeing to to do this. We really appreciate it. 11 Today I am speaking on behalf of two 12 organizations. I am representing the Redwood Alliance. 13 And I am also testifying on behalf of the Sierra Club, N. 14 who have asked me to represent their views today. 15 I have some written comments that I will 16 be submitting jnto the record. 17 The Redwood Alliance and the Sierra Club 18 believe that the following issues should be discussed and 19 fully analyzed by the NRC staff in the Environmental 20 Impact Statement. 21 I will read through a list for you gentlemen 22 that is fairly specific, but I would like to point out 23 before I begin that there may be, and will be, other issues (- 24 that come up throughout this process that we will be 25 commenting on; however, this is a good start, we feel.
32 1 First is the ability of the spent fuel storage 2 facility to withstand the effects of the maximum possible r - 3 earthquake for the Unit 3 plant site. 4 Two, the probability of a destructive earthquak e 5 occurring on or nearby the faults adjacent to the site 6 of Unit 3 within the proposed thirty-year time frame. 7 Third, the possibility of human and 8 environmental contamination in the event of a rupture of 9 the spent fuel storage facility. 10 Fourth, the possible consequences, including 11 a " worst case scenario" of such an accident. 12 Fifth, the presence, effects and behaviors 13 of so-called " activation elements" in the steel, concrete, I\c
- 14 control and other mechanisms located at, and to be stored 15 at, Unit 3.
16 Sixth, the relationship between the existence 17 and'the effects of the activation elements and the perceived 18 need to delay the dismantling of Unit 3 for thirty years. 19 And to that point I would like to just mention 20 that it is our understanding that many' of the techniques 21 by which reactors are dismantled are done remotely and 12 do not involve direct hands-on worker activities. 23 Seventh, a risk / benefit analysis involving 24 the benefit of delaying dismantlement for thirty years 25 as opposed to the risks associated with seismic and
33 1 radiologic hazard, which the public, both directly and 2 through the delayed effects manifested through environmental 3 ' contamination, may endure.
, 4 Eighth, the extent of the leak of the spent 5 fuel storage facility; the rate of radioactive release 6 to the environment; the identify of the isotopes being 7 released; and an inventory of the human and animal impacts 8 involved with the leak.
9 Ninth, the projected status of this leaking 10 spent fuel storage pool. 11 Tenth, the extent, if any, of groundwater 12 contamination at or near the plant site. 13 Eleventh, the effects and projected effects
- 14 of the present leak, both to the human population and the , '~
15 environment, currently and over time. 16 Twelfth, the potential for airborne releases 17 of radiation via Unit 3's stack, both over normal storage 18 operations or in the event of an extraordinary situation, 19 such as the mishandling of radioactive materials -- which 20 has occurred -- or an' earthquake damaging the storage facilit.y , 21 reactor, or other operations of the facility. 12 The projected amounts and isotopes of , 13 radioactive materials expected to be released through the 24 stack under normal conditions.
- s. ,
15 Thirteenth, the maintenance of adequate
34 1 monitoring systems, including those for airborne releases 2 of radiation, necessary to provide early warning for the 3 population of the area in the event of a mishap, either 4 by human error or seismic activity. 5 Fourteenth, the examination of barge 6 transportation of the nuclear waste as opposed to land 7 transportation of such wastes over Humboldt County's 8 occasionally closed and chronically in disrepair road system. 9 Fifteenth, the analysis of alternatives to 10 leaving spent fuel stored in a leaking and seismically liable 11 facility, such as the trancpertation to and storage of 12 these wastes at federal facilities operated by the 13 Departments of Energy and Defense. 14 These facilities are being utilized to house 15 the wastes being generated by the decommissioning of the 16 Shippingport Nuclear Power Plant and could, conceivably, 17 be made available to receive the Unit 3 spent and partially la irradiated fuel, as well as those materials presently stored 19 .in the spent fuel storage facility which could cause a 20 release of radiation to the environment. 21 Under present circumstances, given the condition 22 of the. spent fue'l storage facility and the proximity of 23 earthquake faults to it, the Sierra Club and Redwood 24 Alliance at this time prefer an option which would, at 25 a minimum, remove the spent fuel from the Humboldt Bay
-_ ,- ,, - - - - - ,--,--------g---, ,e -- - -,
r; - . 35 1 Unit 3 site, and which would allow the dismantling of the 2 Humboldt Bay reactor at the earliest feasible date. 3 A thorough examination of the risks associated 4 with the SAFSTOR proposal as advanced by Pacific Gas and 5 Electric Company, outlined by the above concerns and which 6 may be further highlighted by other findings derived from 7 the compilation of the Environmental Impact Statement, will 8 we feel indicate that fuel removal and early dismantling 9 will provide the most prudent course of action from the 10 public standpoint. 11 The public did not bargain for more than 12 100 nuclear te sites scattered throughout the country. 13 Humboldt Bay represents the first of such waste' sites,
! 14 should the SAFSTOR process become conventional wisdom for 15 decommissioning.
16 If possible, all sites, beginning with Humboldt 17 Bay, should be cleaned up to the point where they may be 15 released for unrestricted use, and reverted to their origina: 19 states. 20 Thank you. 21 MR. RENNER: Thank you, Mr. Zichella. 12 Mr.. Larry Goldberg. 13 MR. GOLDBERG: Good evening, and thank you 24 for presenting this opportunity for us to appear today. 25 My name is Larry Goldberg. I am a private citizen living
f 36 1 in Trinidad, California, approximately 35 miles down wind 2 from the Humboldt Bay Nuclear Power Plant. 3 I would like to thank the Staff of the Nuclear { 4 Regulatory Commission for agreeing to hold scoping hearings 5 on the proposed decommissioning of the Humboldt Bay Nuclear 6 Power Plant. . 7 These hearings are of critical importance, a not only to locally concerned citizens but also to all 9 Americans living in proximity to nuclear facilities. 10 The resolution of this issue will affect 11 not just us but our children, our children's children and 12 potentially tens of generations into the future. 13 The Humboldt Bay nuclear reactor presents
- 14 an opportunity for learning the costs, safety issues and 15 technological opportunities facing the nuclear industry 16 for the next hundred years.
17 Our foresight and prudent decision making la can save millions of dollars to California ci*izens, or 19 could potentially lead to economic disaster -- as we have ! 20 ' witnessed recently with the Washington Public Power Supply 21 System and Commonwealth Edison. 22 The most certain thing we can currently agree 23 upon, whether we support the utility's allegations or if 24 you believe in the environmentalists' " worst case scenarios," 25 is that no one currently knows what the cost, what the
37 1 technological issues or the safety concerns will be during 2 t'he decommissioning process. 3 Using common sense, which unfortunately is 4 a? 6.oo uncommon today, one should weigh the veiled 5 ._ tainty of delay with the certainty of dealing with 4 the problem today. 7 As a ratepayer, environmentalist and local 8 citizen I urge the NRC to consider the consequences of 9 postponing decommissioning through adopting the SAFSTOR 10 methodology rather than immediately dealing with the 11 pressing issue of disposal of the dangerous radioactive 12 wastes today. 13 In economic terms the society may benefit 5 < 14 to a significantly greater degree by makir.g the investment 15 today in a decommissioning rather than waiting, as the 16 utility argues, for some future site to be approved for 17 spent fuel storage. The risks of waiting are simply too 18 great in this case. 19 Humboldt Bay Nuclear Power Plant was 20 inappropriately sited in a most unsuitable location. 21 Admittedly, the total accumulated knowledge at the time 22 was considerably.less than today, but this does not excuse 25 the continuation of this time bomb which is located in 24 one of the most active seismic areas in the world. 25 Using the Humboldt Bay plant as a test vehicle e
l . . . 38 1 for decommissioning will lend to the learning curve on 2 the technology of decommissioning, which will be a necessary 3
- transfer to the plethora of existing nuclear power facilities.
4 located nationwide. 5 Are we to expect that once Peach Bottom, 6 Enrico Fermi, Diablo Canyon, Limmerick or any one of the 7 hundred-plus nuclear power plants existing in this nation 8 run out of their useful life that they too will lie dormant 9 for thirty years or so until they cool down, and then have 10 time for us to locate a repository for their wastes? 11 Tne message of the American people is clear: 12 Nuclear power is not cheap it is not clean; and it poses 13 a significant hazard to human endeavor today and forever.
.. 14 We must not allow this mistake to clutter 15 our land like one more auto junkyard. A junkyard poses l
16 no significant risk to thousands of people; a reactor does. l 17 In informal studies conducted by the Redwood 18 Alliance, which is a local citizens' public interest group, 19 two series of balloon releases were conducted over several 20 years. 21 (Chart) 12 Cards were attached to balloons which were 25 released from the Humboldt Bay reactor. Over 2,000 balloons 24 were released. And within hours we were getting cards 25 and calls from the public all over this area (indieating)
r 39 a. 1 and outlying areas reporting the status of the balloons. 2 Within days cards were picked up well into 3 Oregon. And as you can see by this map, this is Eureka, 4 within the first day Trinidad, Willow Creek and even points 5 up near Gasquet, which are well up in the hills, received 6 them the first day. 7 Within the week as far north as the northern 8 tip of Nevada received the balloons that we had sent out. 9 By the end we received responses from over 500 miles away to in some of the most remote.and rugged country you can imagine. 11 And these cards (indicating) document our 12 findings. Now, this is not a scientific study, but just is as an infor= 1 study from a public interest group I think 14 that this has some bearing. 15 The threat posed by airborne releases, water 16 table discharges and other still-uncertain possibilities 17 affect too great a region. ! 18 The cost of the externalities, ranging from l 19 worker exposure to groundwater contamination to yet unforeseen 20 possibilities, force us to petition you to require the
- 21 utility -- Pacific Gas and Electric Company -- to re-evaluato l
, 22 the cost effective analysis to determine if, indeed, it l' 13 may be' cheaper, safer and in the public interest to deal l 24 with decommissioning now while workers at the plant, who 25 know the plant, who understand its operation, can work
/w
r 40 I directly in its dismantlement and removal to safer locations. 2 I recommend that the Nuclear Regulatory 3 Commission mandate the federal repository at Hanford, , 4 Washington to receive and store the spent fuel, contaminated 5 materials and reactor materials from the Humboldt Bay Nuclea2 6 Reactor. 7 To postpone taking this action would be a , 8 criminal-act for one generation to force on another. We 9 must deal with our mistakes in our time; let the future 10 deal with those of their own making. 11 MR. RENNER: Thank you, Mr. Goldberg. 12 Debby Harrison. 13 MS. HARRISON: Hello. I come to you as a 14 health care provider. I work in medicine, and my main 15 concern is that the health and well-being of the workers 16 who will be required to dismantle the plant and the residentt 17 of this area be addressed in the EIS'. 18 That is really all I wanted to say. 19 MR. RENNER: Thank you. 20 Mr. Bob "C.J." Speciale. If I do not pronounce : 21 your name correctly, please give your name correctly at 22 the podium. . 23 MR. SPECIALE: I will just be appearing here 24 as C. J. representing the Earth Party. And I have a couple 25 comments. And I guess this is the Thanksgiving / Christmas
f . 41 1 period. People are thanking each other. I guess I thank 2 God for the opportunity to express my opinion here and 3 of the solutions, and thankful to the wisdom of the NRC 4 for appearing at a public meeting. 5 I think that our position is that we would 6 recommend and feel better with safer inland uninhabited 7 area small site opposing dense-pack type of areas where 8 y..u would recruit wrap-around monitor workers and possibly 9 something like a southern desert area where you could also 10 generate solar -- put in solar generation units, maybe 11 something like Death Valley where you don't even have to 12 worry that much about the water runoff. 13 In terms of cost efficiency when you think 5,_ 14 of the public safety involved in, you know, cost efficiency 15 becomes very, you know, efficient. I think that the site 16 should be sort of temporary but permanent into kind of l 17 the 21st. century, but with the fuel being retractable in 18 case they want to use it for deep space space ships or 19 something blasted off the planet, take it off at that time. 20 For transport, to move it out of the area, 21 I'd go with moving it by helicopter, and moving it that 22 way. 23 And the last comment would be that the present 24 nuclear reactors are obsolete and more dangerous than 25 anything. Thank you.
r o o 42 1 MR. RENNER: Thank you, Mr. Speciale. 2 LeAnna Carson-Hansen.
/ 3 MS. CARSON-HANSEN: Good evening, Commissionero .
4 And thank you, Mr. Renner, for chairing this event this 5 evening. 6 I work currently as a part time office 7 coordinator for the Redwood Alliance. And I have a lot 8 of contact with the community. 9 And the Redwood Alliance is trying to 10 facilitate information from the NRC to the public. And 11 we appreciate your timely notification of this meeting. 12 We hope it continues in the future for meetings that will 13 be upcoming. 14 And we are very concerned about the current 15 status of this spent fuel pool, as Carl Zichella stated 16 earlier. And many of the citizens I have talked with are 17 very concerned about the soundness of the pool to withstand 18 any type of seismic activity in the future, whether minor 19 or major. 20 And in the recent weeks I have been in contact 21 with Fields Landing residents who live right across the 22 street from the. plant. And one particular woman called 28 about three weeks ago because she had been reading and 24 hearing rumors that there is onsite radiation and that 25 the spent fuel pond had been leaking.
r 43 1 And she was concerned specifically about 2 her source of water. And she was under the assumption 3 that her water came from the Humboldt Bay Municipal Water 4 District well, which is located in close proximity to the 5 plant. 6 And after trying to track down where her 7 water source was from -- if it was from the Mad River or 8 if'it was from groundwater -- I was able to get a very 9 cooperative response from the water district, or the 10 California Water Quality Contrcl Board. 11 And we hope to have more information for 12 her in the future, but she is concerned whether or not 13 she should be using this water to bathe her children and b- 14 to feed -- do food preparation. 15 And concerns like this come up to us a lot. 16 And we appreciate the communication that the NRC has had 17 with us. And we hope that the county and state agencies 18 can continue to give us more quick responses when we make 19 requests for the citizens. 20 We feel that the scope of the Environmental 21 Impact Statement must include stringent procedures and 22 safeguards to ensure the protection of the groundwater,' 23 bay and the wetlands. 24 We also feel that there must be an easily 25 implemented evacuation process in the event of any release
44 1 of radioactive elements into the atmosphere, groundwater f 2 or bay, and that periodic drills to familiarize the immediate 3 citizenry be instituted as soon'as possible. 4 We feel these plans and procedures must be 5 made av.ailable in an easily understood vocabulary and be 6 available not just in the Humboldt County Library but to 7 the P.T.A.'s, the City Councils and to different community 8 groups so that this information does not have to be hunted 9 up in the library. 10 .There is a lot of people that can't make , 11 it into Eureka because of transportation concerns. We 12 have a lot of people who are very -- they are close to 13 the poverty line. And it is really hard for them to get l .< . 'k - 14 into Eureka. 15 These plans are real important. And we feel 16 that when people come to us they are not trying to come 17 out of fear; they are coming out of concern. And I do l 18 not feel that fear should be the focus. 19 I think education and confidence in our 20 Nuclear Regulatory Commission and the county response to
- 21 any type of accident is really important.
12 The Redwood Alliance would like to remind 15 our elected officials, Mr. Erickson and the community,
\ 24 that we would like to see a continued open and consistent 25 communication and information dissemination on the
N IMAGE EVALUATION o g // : ? >,, ,,,,,-,,<.,.,
, M.4{g,,
+ .
1.0 lf 23a Eu 6 9 N?E l,l [!E Ese g I.25 1.4 L6 4 150mm > 4 6" >
*r %4 ++J'o//s 4>#gy.,Kr///z
~.- # as 4,\g ev 7/ #44<p#&
o i' t . A .= J
t 45 1 decommissioning of this plant, all phases of it. 2 In closing, we would like to thank Supervisor
^
- 3 Renner again for agreeing to chair this event. And we 4 would like to thank the community for coming out in full 5 force. And we know that there are many people who are 6 at home because they could not come tonight. And we feel 7 this a very historic and important meeting. And we hope 8 that future meetings will be as well attended.
9 I think you for your attention. I 10 MR. RENNER: Thank you, Ms. Hansen. 11 Scott Fielder. ; 12 MR. FIELDER: Good evening. I wanted to 13 thank the Commissioners also for making this meeting l _ 14 available to the public so that we can put on the record 15 our concerns about the Humboldt Bay reactor and how it 16 is going to be handled and how it is going to be decommissior ec 17 My name is Scott Fielder. I am a resident 18 of Blue Lake. And I am also the attorney for the Redwood 19 Alliance in the parallel Public Utility Commission hearings 20 that are covering the manner in which financing the 21 decommissioning of Humboldt Bay will be handled. 22 I wanted to emphasize -- there has already 23 been quite a few eloquent comments about all the issues i'
'- 24 to be covered in the EIS, but there is one area I wanted 25 to add some emphasis to.
i . . 46 l 1 During the trial in San Francisco that I 2 was in attendance in one thing became pretty clear in the 3 evidence, and that was that the plant was surrounded by 4 what I would characterize as a dangerous halo of active 5 earthq' lake faults, including the bay entrance fault which 6 is only 2,000 feet from the plant; the Little Salmon fault, 7 which is also 2,000 feet from the plant; the Gooner (phonetic') 8 Point fault; the North Spit fault; the Matall (phonetic) 9 fault; the Mad River fault; the Corabel fault and the Russ 10 (Ph onetic) fault. 11 The plant, when it was originally designed, 12 was designed to withstand an earthquake that could generate 13 a capacity of point two five ob, which is an operating -- (_ 14 it could operate through a two point -- a point two five g 15 earthquake, and it could be safely shut down if the 16 earthquake did not exceed a point 50 of gravities, which 17 if you translate that to the Richter scale, that meant 15 that it could withstand a six point five earthquake on 19 the Richter scale. 20 Unfortunately, as time has passed and these 21 other earthquake faults were discovered in close proximity 22 to the plant, in the NRC Staff's opinion and the California 23 Division of Mines' opinion, the design of the plant, 24 including the spent fuel pool repository, was clearly not 25 sufficient to withstand the maximum credible earthquake
~
f . \ 47 e 1 risk there. 2 They believe -- they positive, and this is 3 the evidence that I am speaking about that was developed 4 in the trial -- it became clear that the maximum credible 5 earthquake was a 70 to a seven point five earthquake. 1 6 And if that wasn't bad enough, which is 7 approximately ten-fold above what the plant was built for -- 8 if that wasn't bad enough, they determined that it was 9 very credible and very possible that surface fracturing 10 of the ground in the plant, its E.l f , could happen under 1 11 certain given circumstances. 12 Surface fracturing is an extremely dangerous 13 risk to the spent fuel pool repository because it could 14 literally split it in half so that in summary, while you 15 gentlemen are going through the EIS process, I would ask 16 that you take a very close look -- pay close attention 17 to the risk of leaving an enormous amount of highly 18 contaminated fuel in a large body of water in a plant that 19 is surrounded by earthquake faults that are clearly capable 20 of generating an earthquake beyond the standard that the 21 plant, including the spent fuel pool repository, was built 22 for. 23 Thank you again very much for coming and
.. 24 listening to our comments. ;
25 MR. RENNER: Thank you, Mr. Fielder.
r- ._ . .. _. _ _ _ _ _ 48 1 Fred Cranston. 2 MR. CRANSTON: Thank you for providing this 3 forum. My name is Fred Cranston. I am a nuclear physicist, 4 and have specialized in radioactivity and in nuclear research 5 reactors for over fifteen years. 6 My first concern is with the lack of information 7 on' activation elements, specifically for the Humboldt Bay 8 reactor. I have scanned the NRC report, the NUREG/CFR 3474, 9 which is of limited value in dealing with the -- and has 10 serious data gaps. 11 This evening's handout is also useless in 12 assisting me in making a reasonable conclusion about SAFSTOR. 13 The EIS should include an inventory of the amounts of the
. 14 various activation nuclides in the reactor by activity 15 and by half-lifes.
16 My second concern is with the continued 17 storage of fission products and transuranics at the site. 18 Again, to be able to make a rational estimate I would need 19 a complete inventory of these. 20 Although there is as yet no long-term storage 21 facility, there should be developed immediately an interim 22 storage facility.in a remote area to receive the. transuranic 13 and fission product materials and get it away from populated 24 areas. 25 It is unconscionable that this extremely 1
7 49 1 dangerous material is stored within less than a mile of 2 a populated area, including an elementary school. 3 The EIS must include provisions for removing 4 the fission products and transuranics post-haste. We have 5 talked about technology and economics. And it may seem 6 strange for a scientist to bring this up, but I think we 7 ought to also deal with morality and ethics in this thing. 8 And I think to include transuranics and fissi5fL 9 products in a SAFSTOR mode is an immoral and unethical 10 act. Thank you. 11 MR. RENNER: Thank you, Mr. Cranston. 12 (Applause.) 13 MR. RENNER: Ladies and gentlemen, please
- \-
14 hold your applause. 15 G. Sakisian; I hope I have pronounced that 16 correctly. Sakeesian (phonetic); is that the correct 17 pronunciation? G. Saskeesian (phonetic)? 18 (Pause.) 19 Jared Rossman. 20 MR. ROSSMAN: My name is Jared Rossman. 21 I represent the Acorn Alliance for Safe Energy from Southern 12 Humboldt County.. 23 I have read this executive summary that we 24 were presented with tonight. This is PG&E's proposal, 25 but PG&E's prior record in Humboldt County has been one of s
50 1 almost unmitigated failure. 2 They failed in assessing the true need of 3 the area for nuclear generated electric power. They just 4 guessed wrong, in the first place. And they admitted that 5 here on page one dash two, paragraph number two. 6 They failed in building this power plant 7 in the wrong place, in the second place; by the bay, 8 surrounded by earthquake faults, in a populated area, right 9 across the road from a school, an elementary school. 10 They failed in creating an edifice that they 11 said was going to last thirty to forty years, which, i'n 12 fact, only was useful for thirteen years and at that, only 13 possibly sixty to seventy percent of the time was it
- k_ . 14 actually producing power.
~
15 They failed in that their plant here was 16 awarded in 1971 the dubious distinction of being the 17 dirtiest plant operating in the United States. 18 They failed in that even this year, as 19 recently as two months ago, in September, they showed that 20 seven years after shutting the plant down they are still 21 being cited for violations. 12 In a surprise visit by the NRC Staff in 23 September PG&E was cited for three violations including 24 radioactive releases; including radioactive material in
, 25 fifty-five-gallon drums, without any labeling.
4 7 ,,._ _ -_ -..._
r 51 1 l And they failed in that they still have no 2 clear sense of how this mess is going to be dealt with. (, 3 And I quote from their own document here: 4 " Evaluation of the consequences of delayed 5 DECON was less specific since the methods of decontamination / 6 dismantlement and the sequences of operations will not 7 be specified until two or three years prior to DECON." 8 That is still twenty-seven years down the 9 line, according to their own time table. 10 They have admitted leaks into the bay. They 11 have been cited for unreasonable exposure of workers. l 12 They have been cited for leaks in,to the air. 13 In other words, they have admitted failing (
- k. 14 in almost every basis of evaluati,ng success or failure 15 of operating a nuclear power plant.
16 The only thing they have not admitted is 17 endangering the people and our future here, and our 18 environment here. They have not admitted they failed. 19 And this lack of honestyt this lack of responsibility; 20 this hoobrus (phonetic) scares us. 21 We do not trust PG&E. We do not trust their 22 data. We do not trust their evaluations, so the first 23 thing that Acorn Alliance would like to ask the NRC, in
~
24 terms of this Environmental Impact Statement, is that all 25 the data and all the interpretations that have been gathered,
r 52 1 prepared and offered by PG&E must be remeasured and 2 reanalyzed by truly independent scientists. 3 We do not trust PG&E. I am afraid to say 4 that these scientists need to be more independent even 5 than just NRC staffers. And with no insult to you 6 gentlement here,-it has been shown all too frequently that 7 the Nuclear Regulatory Commission is as interested in 8 promoting nuclear power as in regulating it, so we ask 9 that rather than PG&E deciding the form and forum for this 10 EIS, rather than PG&E deciding what is safe as versus what 11 is cost effective, that a truly independent staff of 12 scientists remeasure and reevaluate the findings that PG&E 13 has made, specifically in its executive summary, those (. 14 cited on page one dash one, the fourth paragraph; page 15 one dash two, the second and third paragraphs; page one 16 dash three, all the paragraphs except the first one; and 17 page one dash four, paragraphs -- the second, third and 18 sixth. 19 In addition, Acorn Alliance would like to 20 go on record echoing a number of sentiments expressed here 21 tonight as saying we would like this plant cleaned up now 22 irrespective of cost, irrespective of cost effectiveness. 23 Remove it from this unstable, populated area. 24 And finally, Acorn Alliance would like to 25 go on record as requesting that the ratepayers of California
r 53 e 1 be required to pay no more than thirteen / thirtieths of 2 the cost of this plant, and nothing of the cost that PG&E 3 has incurred since 1973 when, by their own internal memos, 4 they admitted that for what has turned out to be the 5 subsequent eleven years their only intent in keeping this 6 plant from being decommissioned at that point was a public 7 relations need to make sure that the people of California 8 still believed in nuclear power long enough for their 9 current plant at Diablo Canyon to be placed into operation. 10 Thank you. 11 MR. RENNER: Thank you, Mr. Rossman. 12 (Applause) 13 Stephen Kennedy. 14 MR. KENNEDY: Commission, I'm Steve Kennedy. 15 The currently leakage of or slow migration of radiation 16 that is occurring now, as we all know -- the increased 17 seismic activity in this site within the next thirty years It is no doubt bound to occur, seeing those levels allowed 19 under Title 10 CFR part 20 appendix B. 20 I do disagree with the partial comments of 21 one of our representatives for removing the waste and 12 transporting that same waste to Diablo Canyon. That area 23 is also an unsafe seismically active area. 24 The return of the unused fuel assemblies 25 to the fuel vendor should take place immediately and m.
54 1 allowing disposal of the spent fuel to an area allowed 2 under Part 60 of Title 10 CFR should also take place. f- 3 Dismantlement and decontamination process 4 should then proceed, which the Bechtel group company says 5 is all very feasible. 6 If entombment is considered then I would 7 stipulate, or it should be a requirement that PG&E should 8 holld its annual company picnics at that site. Thank you. 9 MR. RENNER: Thank you, Mr. Kennedy. 10 James Adams. 11 MR. ADAMS: Good evening. Most of my comments 12 have been addressed by other speakers, so I will just mentior 13 a couple of things. 14 My name is James Adams. And I live outside 15 of Trinidad. And I was co-founder of Redwood Alliance 16 back in 1978. 17 , One of our, original goals was to ensure that 18 the Humboldt Bay Nuclear Power Plant did not open, and 19 that we address the issue of decommissioning. And it is 20 . good to see that process starting in a real way. 21 Regarding the seismic issue, I do not know 22 if you gentlemen are aware that we had an earthquake in' 23 1980 approximately thirty miles west of Trinidad. And 24 it was a seven point one on the Richter scale. And a bridge 25 on Highway 101 collapsed within one mile of the plant.
m 55 1 And there is no doubt if that quake had been 2 . closer to the Humboldt plant we would probably have had 3 a fracture of this spent fuel pond. 4 For this reason, among many others, we don't 5 want it stored there for thirty years. 6 Secondly, I would like to quote from the 7 Wall Street Journal article dated Friday, December the 8 16'th, 1983. It says according to -- and I quote: 9 According to NRC studies quick dismantlement 10 of some old nuclear power plants would be 11 cheaper than keeping them in mothballs. 12 A plant's recently operating workforce would 13 know the whereabouts of every nut and bolt,
-k. 14 unlike a' demolition crew of strangers decades 15 hence. And the owner would save the expense 16 of keeping guards and janitors on t.he payroll, 17 but because there has been little actual 18 decommissioning work costs remain a big 19 question mark."
20 We feel that the only way to determine just 21 what costs are entailed in this sort of operation is to 22 actually get down and do it, not waiting for twenty-seven 23 years before you figure out exactly what you are going 24 to do. 25 Finally, I would like to close with, again,
c 56 1 tl..nks for allowing this process to happen. We hope that 2 the draft EIS will come out -- we have not heard any time 3 tables yet. I originally heard one year from this past 4 September. 5 Be that as it may, I assume that there will 6 be public hearings here to review that document. At that 7 time we will have both oral and written comments. Thank 8 you. 9 MR. nENNER: Thank you, Mr. Adams. 10 MR. ERICKSON: This is Erickson. I can give 11 you a time on our draft Environmental Impact Statement. 12 Our target date is March 31, 1985. For the final 13 Environmental Impact Statement our target date is July 31, a i 14 1985. 15 MR. RENNER: Mr. Mark Mullins. 16 MR. MULLINS: Helle. I am Mark Mullins. 17 And' I have made lots of phone calls to the NRC. And there 18 is a phone number that has a Region Five status report, 19 which I think you know of. 20 And I would call up. And I do not find any 21 word about the Humboldt plant, which is -- I called and 22 asked why. And they tell me that it is not producing 23 electricity so it does not need to be on the report.
\
24 Well, my concern is I would like to have 25 that available to the public on the phone because it is a i
f 57 I critical plant. And as this decommissioning goes on, no 2}}