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Pacific Gas and Electric Compaay 77 Bea'e Sheet James D. ShrerSn FrarvJsco. CA M106 V(e hetent415/973 / 684 Nx: ear Power Gererabon

TNX 91037? 6'87

September 13, 1988

PG&E Letter No. HBL-88-077

U.S. Nuclear Regulatory Commission ;

ATTN: Document Control DeskHashington, D.C. 20555

Re: Docket No. 50-133, OL-DPR-7,

Humboldt Bay Power Plant, Unit 3Exemption Request, 10 CFR 70.51(d)

Gentlemen: |,

In accordance with the provisions of 10 CFR 50.12. "SpecificExemptions " PG&E requests an exemption from the provisions of:

10 CFR 70.51(d) which pertains to the annual physical inventory of';

spent fuel. PG&E .neets the applicable exemption criteria of10 CFR 50.12 as discussed below.

:10 CFR 50.12(a)(1)

This exemption will not present an undue risk to the public healthand safety. By performing the annual physical inventory as proposed.

in PG&E Letter No. HBL-88-055 dated June 6, 1983 (Enclosure 1),radiation exposures to workers will be minimized.

1

In preparation for SAFSTOR, a cover hat been installed over thespent fuel storage pool and secured by tamper-indicating seals to

i prevent contaminants t' rom entering the pool and to prevent the: spread of contamination from the pool to the surrounding building.

Since it is proposed to perform the annual inventory by inspectingthe integrity of the cover and seals, which does not introduce'

additional special nuclear material intc,t'e pool, there is noimpact on the health and safety of the pubi:t in allowing the,

! required inspection to be done in this manner. The proposed methodof meeting the inventory requirements of 10 CFR 70.51(d) does not

! involve a significant increase in the probability or consequence ofi an accident previously evaluated, does not create the possibility of; a new or different kind of accident from any accident previouslyI evaluited, and does not involve a significant reduction in a margin

of safety.

PG&E has determined that this exemption will not affect theenvironm ntal analysis in the SAFSTOR Decommissioning Plan, theEnvironmental Report '.) the Decommissioning Plan, or the FinalEnvironmental Statement for Decommissioning HBPP Unit 3 since theexemption would involve no increase in the amounts and no change inthe types of effluents that may be released offsite. Further, there

| is no increase in individual or cumulative occupational radiationexposure. Rather, there will be a decrease in occupational exposure'

8809220206 880913 gg|i DR ADOCK 0500 33;

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Document Control Desk -2- September 13, 1988PG&E Letter No. HBL-88-077 ;

associated with this task. Therefore, there are no unreviewed environmentalquestions involved.

10 CFR 50.12(a)(2)

| PG&E believes that conducting a physical inventory of special nuclear materialstored in the fuel pool as provided in 10 CFR 70.51(d) is not necessary toachieve the underlying purpose of the rule since performance of the annual ,

inventory by inspecting the integrity of the cover and seals, as proposed,would satisfy the inventory requirement. The unit is in a SAFSTOR status andall spent fuel has been removed from the reactor and placed in the spent fuel .

pool. As indicated in Enclosure 1, no additional fuel assemblies will be,

placed in the pool. The only anticipated occasions when the cover will be'

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| routinely removed will be for retrieval of neutron absorbing material sample I

coupons suspended in the pool (or monitoring purposes. This activity will be

j performed at 5-year intervals according to the Technical Specifications.

| Based on the foregoing reasons, PG&E believes that it has satisfied the ,

requirements of 10 CFR 50.12 for exemption from 10 CFR 70.51(d). Timely ;'

' granting of this exemption would be appreciated.

Kind 1y acknowledge receipt of this material on the onclosed copy ofthis letter and return it in the enclosed addressed envelope.

Sincerely,

!

4

*J. D. Shi er!

: cc: P. B. Ericksoni R. A. Erickson !

: J. B. Hartin .

J G. B. Nelson !

Humboldt Distribution ,

fEnclosures

22805/0063K/PLP/1739

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PG&E Letter No. HBL-88-077*

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ENCLOSURE 1

PGLE Letter No. HBL-88-055, June 6,1988*

22805/0063K

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ENCLOSURE 1

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Poemc tas med Electric Company 71Beav St ett Jame . 0 SW-Saa Trav,:: CA 941X V(e Prewet415 9') AU: N.r.iea Pc6e Ge et.:-TWx 910 372 E5P

'.

June 6, 1988

PG&E Letter No. H9L-88-055 .--

U.S. Nuclear Regulatory ComissionATTN: Document Control DeskHashingtor., D.C. 20555

Re: Docket No. 50.133, OL-DPR-7Humboldt Bay Power Plant, Unit 3Annual Physical Inventory

Gentlemen:

PGLE requests your concurrence to utilize security seals on thespent fuel storage pool at Humboldt Bay Power Plant, Unit 3(HBPP-3). The use of the seals will simplify the annual physicalinventory of the spent fuel stored in the pool and thereby minimizeradiation exposures to workers and the unnecessary spread ofcontamination within the facility.

HBPP-3 is currently in the process of being decommissioned. Thefacility operating license was amended in July 1985, to &1 lowpossession but not operation of the facility, and PG&E is currentlyawaiting NRC approval of the SAFSTOR Decomissioning Plan. TheSpecial Nuclear Material (SNH) inventory at HBPP-3 includes 390spent fuel assemblies stored in the faellity spent fuel storagepool. These fuel assemblies will remain onsite until the Departmentof Energy has a spent fuel repository in operation and is ready toreceive the fuel from Humboldt Bay.

In preparation for SAFSTOR, a cover has been installed over thespent fuel storage pool to prevent contaminants from entering the

l pool and to prevent the spread of contamination from the pool to thesurrounding building. Previous annual SNH inventories have includedvisual identification of individual fuel assemblies in the pool.Under current conditions this would require removal of the poolcover. This practice not only increases the potential for thespread of contamination from the pool but also increates radiation

| exposure to workers handling the cover Lne perferming the inventory.

Since no additional fuel assemblies will be placed in the pool, theonly enticipated occasions when the cover will be routinely removedw111 be for retrieval of neutron absorbing material sample coupons

| which are suspended in the pool and will be required to be monitoredperiodically by the HBPP-3 SAFSTOR Technical Specificatio'is. Thisactivity will be performed at approximately 5-year intervals.

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Document Control Desk -2- June 6, 1988'*

PG&E Letter No. HBL-88-055

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In order to eliminate unnecessary rewaval of the spent fuel cover, PG&Eproposes to install tamper-indicativj seals on the cover and to perform theannual SNH inventory by insperting the integrity of the cover and seals. Theuse of seals will be in compliance with ine applicable portions of RegulatoryGuide 5.15. "Securit.v Seals for the Protection and Control of Special NuclearMaterial.' PG&E has discussed this proposal with Gilbert Nelson of the NRCRegion V office and expects to implement this procedure in July 1988,following the next annual phystral inventory at the facillt:s. Timely NRCconcurrence for PG&E's use of this procedure at HBPP-3 would be appreciated.

Kindly acknowledge receipt of this material on the enclosed copy of thisletter and return it in the enclosed addressed envelope.

Sincerely,,

J. D. Shiffer

cc: P. B. EricksonR. A. EricksonJ. B. MartinG. B. NelsonHumboldt Distribution

21485/0060K/PLP/1739

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PG&E Letter No. H8L-88-077*

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ENCLOSURE 2

PGLE Letter No. HBL-88-066, July 19, 1988*

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| 22805/0063K

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l* ENCLOSURE 2

PacMc Gas and Doctric Campany 77 BWe Sriett JamesD Ser*

San frawo CA9496 vce F tweat,

415-Q73 4f.64 Nxw Pent' Gent at:nTWK 90 372 6%7

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July 19, 1988

PG&E Letter No. H8L-88-066 !

U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashirigton, D.C. 20555

Re: Docket No. 50-133. OL-DPR-7Humboldt Bay Power Plant Unit 3Annual Physical Inventory

Gentlemen:

As requested by the NRC Staff in a letter dated June 21, 1988, PG&Eis providing the enclosed additional information regarding use ofsecurity seals on the spent fact storage pool at Humboldt Bay PowerPlant Unit 3.

Kindly acknowledge receipt of this material on the enclosed copy ofthis letter and return it in the enclosed addressed envelope.

Sincerely.

*.

J. D. Shiffer

cc: P. B. EricksonR. A. EricksonJ. B. MartinG. B. NelsonHumboldt Distribution

Enclosure

22165/0061K/EHG/1739*

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PG&E Letter No. HBL-88-066.

ENCLOSURE

NRC 00MMENT 1

"The Regulatory Position stated in Section C of RegulatoryGuide 5.15, entitled, "Security Seals for the Protectionand Control of Special Nuclear Material," dated January1974, shall be adhered to;"

PG&E RESPONSE

PG&E agrees to adhere to Regulatory Guide 5.15, dated January 1974, with thefollowing exception.

Section C.1.c.

This section requires that Type E seals must have a brass top and copperbottom. The seal to be used by PG&E comes only with a copper top andbottom. Therefore, PG&E will be using Type E cup seals with copper topsand bottoms and steel inserts. instead of brass and copper seals withbrass inserts. In addition, PG&E understands that seals of this type arealready in use in a similar application by Advanced Nuclear FuelsCorporatica of Richland, Washington.

NRC COMMENT 2

"A physical inventory of all spent fuel shall be conductedwhenever a seal has been found to be comprised (sic);"

PG&E RESPONSE

PG&E agrees to conduct an inventory of the spent fuel storage pool whenever aseal is compromised.

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NRC COMMENT 3

"Seal number and integrity shall be verified every 12months;"

PG&E RESPONSE

PG&E will verify the seal number and integrity every 12 months.

22165/0361X -1-

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( NRC COMMENT 4

"A physical inventory of all spent fuel shall be conductedafter an authorized opening of the cover in which theperiod of time since the last inventory is in excess of 12months;"

PG&E RE3PONSE

PG&E will perform a physical inventory of the spent fuel after an authorizedremoval of the cover if the time since the last inventory is in excess of 12months.

NRC COMMENT 5 ,

"Two authorized individuals shall remain in the area of thespent fuel sto; age pool when the cover is removed and theperiod of time since the last inventory is less than 12months, and the same two individuals shall attest inwriting that no fuel was temoved from the pool.Alternatively, an inventory of all spent fuel shall be

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conducted."

. PC&E RESPONSE

A physical inventory of the spent fuel shall not be required after anauthorized removal of the cover, provided:

1. That the time period since the last inventory is less than 12 months;I

2. Any entry into the refueling building while the cover is removed was madeby at least two authorized individuals who shall attest in writing thatno spent fuel was removed from the pool while they were in the refuelingbuilding; and ,

3. While the cover is removed and in the absence of at least two authorizedindividuals in the refueling building, the alarms, cameras end otherdetection devices that make up the, security system must be OPERADLE and

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maintained in accordance with the security plan.

Alternatively, an inventory of all spent fuel shall be conducted.

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