ML20073K740

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Defueled Safety Analysis Report (Dsar), Revision 13
ML20073K740
Person / Time
Site: Humboldt Bay
Issue date: 02/24/2020
From:
Pacific Gas & Electric Co
To:
Office of Nuclear Material Safety and Safeguards
Shared Package
ML20073K738 List:
References
PG&E Letter HBL-20-004
Download: ML20073K740 (18)


Text

DEFUELED SAFETY ANALYSIS REPORT TABLE OF CONTENTS Section Title Page CHAPTER 1. INTRODUCTION AND

SUMMARY

1.1 INTRODUCTION

1-1 1.2 SITE CHARACTERISTICS 1-2 1.3 QUALITY STANDARDS 1-2 1.4 FIRE PROTECTION 1-2 1.5 CONTROL OF RELEASES OF RADIOACTIVE MATERIALS 1-2 1.6 PERSONNEL SELECTION AND TRAINING 1-3 1.7 REPORTING OF OPERATING INFORMATION 1-3 1.8 MEASURING AND REPORT OF EFFLUENTS FROM NUCLEAR POWER PLANTS 1-3 1.9 IDENTIFICATION OF AGENTS AND CONTRACTORS 1-4 1.10 CONCLUSIONS 1-4 CHAPTER 2. SITE AND ENVIRONMENT 2.1

SUMMARY

2-1 2.2 SITE AND ADJACENT AREAS 2-1 2.3 METEOROLOGY 2-1 2.4 HYDROLOGY 2-1 2.5 ENVIRONMENTAL MONITORING PROGRAM 2-2 CHAPTER 3. STRUCTURES 3.1 RADWASTE TREATMENT FACILITIES 3-1 i REVISION 13

DEFUELED SAFETY ANALYSIS REPORT TABLE OF CONTENTS Section Title Page CHAPTER 4. AUXILIARY SYSTEMS 4.1 GENERAL 4-1 4.2 FIRE PROTECTION PROGRAM 4-1 CR 13-01 CHAPTER 5. RADIOACTIVE WASTE AND RADIATION PROTECTION 5.1 RADIONUCLIDE INVENTORY 5-1 CR 5.2 SOLID WASTE MANAGEMENT 5-1 13-01 5.3 OFF-SITE DOSE CALCULATION MANUAL 5-1 CR 13-01 5.3.1 Liquid Discharge Pathway 5-1 CR 13-01 CR 5.3.2 Gaseous Discharge Pathway 5-2 13-01 CR 5.4 RADIATION PROTECTION PROGRAM 5-2 13-01 CR 5.4.1 Organization 5-2 13-01 CR 5.4.2 Equipment and Instrumentation 5-2 13-01 CR 5.4.3 Radiation Protection Procedures 5-2 13-01 CHAPTER 6. CONDUCT OF OPERATIONS CR 13-01 6.1 PLANT ORGANIZATION 6-1 6.2 PERSONNEL TRAINING 6-1 6.3 EMERGENCY PLAN 6-1 ii REVISION 13

DEFUELED SAFETY ANALYSIS REPORT TABLE OF CONTENTS Section Title Page 6.4 PLANT PROCEDURES 6-1 6.5 RECORDS 6-1 CHAPTER 7. SAFETY ANALYSIS 7.1 DECOMMISSIONING ACCIDENT ANALYSIS 7-1 APPENDIX A DSAR SUPPLEMENT, LICENSE TERMINATION PLAN A-1 iii REVISION 13

DSAR CHAPTER INTRODUCTION AND

SUMMARY

1.1 INTRODUCTION

In 1984 PG&E submitted the Humboldt Bay Power Plant, Unit 3 (referred to as either HBPP, Unit 3, or the Humboldt Bay nuclear facility) SAFSTOR Decommissioning Plan (SDP) in support of the application to amend the HBPP Operating License to a Possession-Only License. As a result of the 1996 NRC decommissioning rule, the SDP was considered to be a Post-Shutdown Decommissioning Activities Report (PSDAR) because it contained information related to decommissioning activities. It was also considered to be a Final Safety Analysis Report (FSAR) because it contained information such as plant description, site characterization and accident analysis. In compliance with the 1996 NRC decommissioning rule, PG&E submitted a PSDAR in February 1998 to provide a general overview of proposed decommissioning activities. As a result, the SDP will focus on providing the type of information contained in an FSAR and will contain less information related to decommissioning activities. Thus, the SDP has been more appropriately renamed the Defueled Safety Analysis Report (DSAR).

In addition to the DSAR and PSDAR, PG&E has submitted other documents to the NRC in accordance with 10 CFR 50 that constitute the licensing basis for HBPP. These other documents include: (1) License Amendments, (2) revised Technical Specifications, (3)

Environmental Report, (4) Quality Assurance Plan, and (5) License Termination Plan. CR 13-01 This DSAR reflects the changes made following Humboldt Bays (HBs) decision to decommission Unit 3 in June 1983, as well as License Condition 2.B.1 that allow Pacific Gas and Electric Company (PG&E) to take actions necessary to decommission and decontaminate this facility. PG&E will update the DSAR in accordance with the methodology specified in 10 CFR 50.59 and 10 CFR 50.71(e), submitting updates at least every two years. Revisions to the DSAR are numbered, starting with Revision 1.

The purpose of the DSAR is to provide a Safety Analysis Report that provides assurance that based on the decommissioning activities and the administrative controls and programs in place during decommissioning, no undue risk to the public health and safety will occur during normal operation and postulated accident conditions.

The following provides a history of major plant operation and licensing-related actions:

1. Unit 3 achieved initial criticality on February 16, 1963 and began commercial operation in August 1963.
2. On July 2, 1976, Unit 3 was shut down for annual refueling and to conduct seismic modifications. Seismic and geologic studies were in progress.

3 In December 1980 it became apparent that the cost of completing required backfits might have made it uneconomical to restart the unit. Work was suspended at that time awaiting further guidance regarding backfitting requirements.

1-1 REVISION 13

4 In 1983, updated economic analyses indicated that restarting Unit 3 would probably not be economical, and in June 1983 PG&E announced its intention to decommission the unit.

5 On December 11, 2008, PG&E completed the transfer of spent fuel from the spent fuel pool into the ISFSI.

1.2 SITE CHARACTERISTICS The Humboldt Bay nuclear facility is located about four miles true southwest of the city of Eureka, Humboldt County, California, and consists of 113 acres of land.

Since there are no design basis accidents that could approach 10 CFR 100 limits, no Safety Features are necessary to keep public exposures below the 10 CFR 100 dose limits under worst case postulated accident conditions.

1.3 QUALITY STANDARDS The Humboldt Bay Quality Assurance Plan (HBQAP) describes the 10 CFR 50, Appendix B quality assurance program for important-to-safety SSCs and activities. Management and administrative program requirements that apply to Unit 3 are subject to administrative controls which demonstrate compliance with regulatory requirements.

1.4 FIRE PROTECTION The Fire Prevention Program describes the overall fire protection program in place at HB.

DSAR Chapter 4 also discusses the fire protection system.

1.5 CONTROL OF RELEASES OF RADIOACTIVE MATERIALS The radiological administrative control programs at Humboldt Bay effectively control the CR collection, segregation, processing, packaging, and disposal of radioactive solids. Programs 13-01 function to control releases to as low as is reasonably achievable levels and are designed to give reasonable assurance that the numerical guidelines defined in 10 CFR 50.34a, 50.36a, and 10 CFR 50, Appendix I, and contained in the Off-site Dose Calculation Manual (ODCM) will be met.

Solid wastes are normally processed in batches for off-site disposal. Gaseous effluents (particulates) could be released during decommissioning activities. CR 13-01 1-2 REVISION 13

1.6 PERSONNEL SELECTION AND TRAINING Plant personnel meet the minimum education and experience standards specified in ANSI N18.1-1971, "Standard for Selection and Training of Personnel for Nuclear Power Plants."

Retraining and replacement training meets or exceeds the requirements and recommendations of ANSI N18.1-1971 for comparable positions. The Radiation Protection Manager shall meet or exceed the requirements of Regulatory Guide 1.8, Revision 2, April 1987.

DSAR Chapter 6 discusses training programs for staff personnel. Records of the qualifications, training, and retraining of each member of the plant organization are maintained in accordance with established programs.

In accordance with 10 CFR Part 19, personnel are provided radiological training commensurate with the hazards to which they may be exposed while working at HBPP.

1.7 REPORTING OF OPERATING INFORMATION The Humboldt Bay Quality Assurance Plan specifies the annual routine reporting requirements.

Personnel radiation exposure and monitoring procedures have been established and reports are submitted, as required.

Reporting abnormal events in Licensee Event Reports and Special Reports is performed by site staff in accordance with established procedures and applicable regulatory requirements.

Established procedures ensure significant events are quickly brought to the attention of management and acted upon within the allowed reporting period.

1.8 MEASURING AND REPORT OF EFFLUENT FROM NUCLEAR POWER PLANTS The measuring and reporting of radiological effluents from Humboldt Bay complies with the requirements of Regulatory Guide 1.21 and the ODCM.

Annual reports summarizing the quantity of radionuclides released from the site are submitted to the NRC in accordance with 10 CFR 50.36a(a)(2). CR 13-01 1-3 REVISION 13

1.9 IDENTIFICATION OF AGENTS AND CONTRACTORS PG&E is responsible for control of agents and contractors used during the decommissioning the Humboldt Bay facility.

1.10 CONCLUSIONS The personnel assembled to decommission Humboldt Bay facility are capable of performing their required project function. The health and safety of the public and plant personnel are among the primary concerns during decommissioning.

The Humboldt Bay facility can be decommissioned in a safe manner and PG&E is qualified to decommission this nuclear facility in accordance with all applicable laws and regulations and in a manner satisfactory to the NRC, the public, and itself.

1-4 REVISION 13

DSAR CHAPTER 2 - SITE AND ENVIRONMENT 2.1

SUMMARY

The Humboldt Bay nuclear facility lies in the Northern California Coast Ranges geomorphic province. This province consists of a system of longitudinal mountain ranges (2000 to 4000 foot elevations with occasional 6000 feet peaks) and valleys with a trend of N 30 degrees to 40 degrees W. Terrain of the site varies from submerged and low tidal land, protected by dikes and tide gates, to a high precipitous bluff along the southwestern boundary.

Elevations range from approximately -3 feet to +75 feet based on a datum of the mean lower low water (MLLW) level.

Soils in the immediate vicinity of the site consist of sand and alluvial soil and strata of the Hookton and Carlotta sedimentary formations. These formations are primarily consolidated sands, gravels, and clays and conglomerates with good engineering properties.

Figure 2-1 shows the general location of the Humboldt Bay site. Figure 2-2 provides a more specific layout of the PG&E-owned land and a general layout of the site.

2.2 SITE AND ADJACENT AREAS The land in the general vicinity around the Humboldt Bay site is presently low density rural housing and is used primarily as grazing areas.

Within a 15-mile radius of the site there are five cities or communities (Eureka, Fortuna, Arcata, King Salmon, and Fields Landing). Activities in the area immediately surrounding the site are not expected to change extensively.

King Salmon Avenue runs along the west side of the site boundary and connects with US Highway 101 which runs along the southern boundary of the site. The Southern Pacific Railroad runs roughly parallel to Highway 101 but is out of service.

PG&E is operating Humboldt Bay Generating Station (HBGS), a new dual fueled (natural gas and diesel) power plant, on the Humboldt Bay site adjacent to the south side of the facility.

The Humboldt Bay ISFSI is located on site approximately 600 feet northwest of the HBGS.

2.3 METEROLOGY The Humboldt Bay facility uses conservative default atmospheric dispersion and deposition CR factors in its evaluations of off-site gaseous releases. 13-01 2.4 HYDROLOGY The surface runoff from the site is directed into drains eventually discharging into Humboldt CR Bay. Outside the area served by the drain system, surface runoff drains into Buhne Slough, 13-01 the natural drainage for the area, which drains into Humboldt Bay.

The nearest streams to the site are Salmon Creek and Elk River, which are within a mile south and north of the site, respectively, and which discharge into Humboldt Bay. These streams are used for watering livestock, but are not used as a potable water supply.

2-1 REVISION 13

The Mad River flows west approximately 13 -15 miles northeast of the site. The Ruth reservoir, the source of the city's water supply, is located on this river.

To the south, the Eel River discharges to the Pacific Ocean 8-10 miles from HB. This river is not used for potable water within 25 miles of HB.

Groundwater elevation in the area near the bay is similar to sea level and may be somewhat CR affected by tidal action. 13-01 2.5 ENVIRONMENTAL MONITORING PROGRAM The environmental monitoring of the environment during decommissioning is delineated in the Off-site Dose Calculation Manual.

Results of the Humboldt Bay environmental monitoring are available to the State of California and federal agencies that have a direct interest and concern in these matters.

2-2 REVISION 13

Figure 2-1 REVISION 13

CR 13-01 Figure 2-2 REVISION 13

DSAR CHAPTER 3 - STRUCTURES 3.1 RADWASTE TREATMENT FACILITIES CR Temporary buildings are used to store low level radwaste packages awaiting shipment. As 13-01 decommissioning progresses, these structures, systems and components will be removed from service. CR 13-01 3-1 REVISION 13

DSAR CHAPTER 4 - AUXILIARY SYSTEMS 4.1 GENERAL The systems considered in this DSAR Chapter are:

CR

1. Fire Protection 13-01 Design changes, modifications, and additions to existing systems and components are reviewed for compliance with the requirements of 10 CFR 50.59 "Changes, Tests, and Experiments."

CR 4.2 FIRE PROTECTION PROGRAM 13-01 The fire protection program describes the organizational requirements, design features, operational requirements, compensatory measures, testing requirements, and off-site fire fighting assistance coordination requirements that collectively define Unit 3s fire protection program. Fire loading, ignition sources, and combustible materials are significantly reduced and the possibility for a major fire is greatly diminished from the unit's operational phase. As decommissioning progresses, the requirements for fire suppression, detection and alarm systems will be removed.

Offsite firefighting capability is provided by the local fire department.

4-1 REVISION 13

DSAR CHAPTER 5 - RADIOACTIVE WASTE AND RADIATION PROTECTION 5.1 RADIONUCLIDE INVENTORY Administrative and engineering controls are utilized to limit airborne radioactivity exposure to CR the workers and general public during decommissioning. 13-01 CR 5.2 WASTE MANAGEMENT 13-01 Radioactive wastes are collected and processed on or off site and shipped to a licensed CR 13-01 and/or permitted burial site for disposal. Off-site secondary processors may be used for CR volume reduction or further processing prior to disposal. Wastes are packaged in containers 13-01 which conform to Department of Transportation (DOT) requirements (49 CFR) for transport to a licensed disposal facility.

The total curie content and major radionuclide composition by waste type are reported in the Radioactive Effluent Release Report required pursuant to 10 CFR 50.36a.

CR 5.3 OFF-SITE DOSE CALCULATION MANUAL 13-01 The ODCM provides the information and methodologies used to evaluate the impact of CR radiological liquid and gaseous effluent discharged. 13-01 The ODCM is used to demonstrate compliance with the requirements of 40 CFR 190 and 10 CR 13-01 CFR 20, and the dose guidelines of 10 CFR 50, Appendix I. Calculations for continuous airborne releases use default atmospheric diffusion coefficients. Exposures due to CR 13-01 decommissioning are estimated by calculation methods specified in the ODCM.

CR 5.3.1 Liquid Discharge Pathway 13-01 Discharge of processed radioactive effluents to Humboldt Bay was terminated. Process water and liquids that exceed the reuse or unconditional release criteria are dispositioned in CR 13-01 accordance with the disposal site waste acceptance criteria.

5-1 REVISION 13

5.3.2 Gaseous Discharge Pathway CR 13-01 Release pathways have been and are expected to continue to be very small; well within the CR 10 CFR 50, Appendix I dose guidelines and 10 CFR 20 concentration limits. 13-01 5.4 RADIATION PROTECTION PROGRAM CR 13-01 5.4.1 Organization The HB Director has the overall responsibility for radiological protection for all onsite activities, including assurance that ALARA policies are carried out at the facility. The Radiation Protection Manager is responsible for specifying radiation protection requirements for work activities. The HBPP organization and reporting chain are specified in administrative procedures.

CR 5.4.2 Equipment and Instrumentation 13-01 Personnel Protective Equipment CR Anti-contamination clothing is available, if necessary to protect personnel against contact 13-01 with radioactive contamination.

Radiation Protection Instrumentation A variety of instruments are used to cover the entire spectrum of radiation measurements at Humboldt Bay.

5.4.3 Radiation Protection Procedures CR 13-01 The radiation protection program is organized to meet the requirements of 10 CFR 20.

CR 13-01 5-2 REVISION 13

DSAR CHAPTER 6 - CONDUCT OF OPERATIONS 6.1 PLANT ORGANIZATION The details of the PG&E organization that oversees the activities at the Humboldt Bay nuclear facility are discussed in administrative procedures. The HB Director heads the on-site Humboldt Bay facility organization and directs the activities of the functional on-site departments.

6.2 PERSONNEL TRAINING Plant personnel are selected and trained for their assigned duties, with each department head being responsible for conducting department training that meets the applicable requirements and standards.

Radiological training is provided to all personnel commensurate to the hazards to which an individual will be exposed. Training is conducted and documented in accordance with the training program.

6.3 EMERGENCY PLAN Radiological source terms which may result in declaration of a radiological emergency are eliminated or administratively controlled to limit potential exposure beyond the site boundary.

6.4 PLANT PROCEDURES The HB Administrative Procedures (HBAPs) define and implement administrative requirements or activities involving inter-departmental processes and administrative responsibilities. Procedure hierarchy, preparation, review, approval, revision, and control are established in accordance with the applicable HBAPs.

6.5 RECORDS Records are maintained as described in administrative procedures.

6-1 REVISION 13

DSAR CHAPTER 7 - SAFETY ANALYSIS 7.1 DECOMMISSIONING ACCIDENT ANALYSIS There are no postulated decommissioning accidents with potential radiological impacts to the environment. The remaining radioactive source terms at the defueled Unit 3 reactor site have been eliminated or are administratively controlled to mitigate the postulated event precursors.

7-1 REVISION 13

APPENDIX A DSAR SUPPLEMENT LICENSE TERMINATION PLAN PG&E originally submitted the License Termination Plan (LTP) on May 3, 2013, in PG&E letter HBL 13-007. As stated in HBL 13-007, the LTP will become a supplement to the DSAR upon approval of the LTP by the NRC. The NRC has approved the LTP.

REVISION 13 A-1