IR 05000133/2012008
| ML12104A064 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 04/13/2012 |
| From: | Spitzberg D NRC/RGN-IV/DNMS/RSFSB |
| To: | Halpin E Pacific Gas & Electric Co |
| References | |
| IR-12-008 | |
| Download: ML12104A064 (16) | |
Text
UNITE D S TATE S NUC LEAR REGULATOR Y C OMMI SSI ON ril 13, 2012
SUBJECT:
NRC INSPECTION REPORT 050-00133/12-008
Dear Mr. Halpin:
This refers to the inspection conducted on March 21-25, 2012, at the Humboldt Bay Power Plant, Unit 3, facility, in Eureka, California. The enclosed report presents the results of this inspection. This inspection was an examination of activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel. In summary, the inspector determined that you were conducting decommissioning activities in accordance with license and regulatory requirements. The preliminary inspection results were presented to your staff at the conclusion of the onsite inspection.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response, if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs documents system (ADAMS), accessible from the NRCs Web site at HTTP://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction.
Should you have any questions concerning this inspection, please contact Dr. Gerald Schlapper, Health Physicist, at 817-200-1273 or the undersigned at 817-200-1191.
Sincerely,
/RA/
D. Blair Spitzberg, PhD, Chief Repository and Spent Fuel Safety Branch Docket: 050-00133 License: DPR-7
Pacific Gas and Electric Company -2-
Enclosure:
NRC Inspection Report 050-00133/12-008
REGION IV==
Docket: 050-00133 License: DPR-7 Report: 050-00133/12-008 Licensee: Pacific Gas and Electric Company Facility: Humboldt Bay Power Plant, Unit 3 Location: 1000 King Salmon Avenue Eureka, California 95503 Dates: March 21-25, 2012 Inspector: Gerald Schlapper, PhD, PE, CHP, Health Physicist Repository and Spent Fuel Safety Branch Approved by: D. Blair Spitzberg, PhD, Chief Repository and Spent Fuel Safety Branch Attachment: Supplemental Inspection Information Enclosure
EXECUTIVE SUMMARY Humboldt Bay Power Plant, Unit 3 NRC Inspection Report 050-00133/12-008 This inspection was a routine, announced inspection of decommissioning activities being conducted at the Humboldt Bay Power Plant (HBPP), Unit 3, facility. In summary, the licensee was conducting site activities in compliance with regulatory and license requirements. A significant activity during this inspection was the removal of the chimney from the reactor vessel. The chimney was located above the reactor core and served as the steam/water separator in this natural convection boiling water reactor. As observed by the inspector, this activity was accomplished per procedures and license and regulatory requirements. The licensee had completed extensive planning for contingencies that should they arise during this activity. However, because the removal was completed as planned and without unanticipated problems, such contingencies were not invoked.
Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors The licensee conducted safety reviews, design changes, and modifications in accordance with license and regulatory requirements (Section 1).
Decommissioning Performance and Status Review at Permanently Shutdown Reactors At the time of the inspection, decommissioning remains on schedule and within budget though the sequence of some activities has required adjustment to accommodate the challenges of scheduling. The licensee is analyzing the removal of subsurface structures for feasibility and cost. Based on results of this study, a path forward will be proposed. This decision could have a significant impact on the schedule and cost of decommissioning. The licensee conducted decommissioning activities in accordance with license and regulatory requirements. Radioactive postings and boundaries were maintained in accordance with regulatory requirements (Section 2).
Occupational Exposure During SAFSTOR and DECON The licensee monitored occupational exposures in accordance with procedures and regulatory requirements. Data supplied by the licensee indicated that the total dose to individuals in the refueling building during the transfer of the chimney from the reactor vessel to the spent fuel pool was 3.3 mRem.
Personnel exposures remain less than estimates and reflect application of ALARA (as low as reasonably achievable) to work activities (Section 3).
Radioactive Waste Treatment and Effluent and Environmental Monitroing The licensee conducted effluent and environmental monitoring in accordance with license and regulatory requirements. Continuation of silt buildup in the discharge canal was noted by the inspector and confirmed by the licensee. The licensee is reviewing the process for discharge of treated and monitored effluent from the liquid radwaste stream due to the significant potential for decrease in dilution in the discharge canal (Section 4).
-2- Enclosure
Solid Radioactive Waste Management and Transportation of Radioactive Materials With the completion of decommissioning of fossil Units One and Two, the frequency of off-site shipments of material has decreased since the last inpection. The licensee conducted radioactive waste management and transportation activities in accordance with regulatory requirements (Section 5).
-3- Enclosure
Report Details Summary of Plant Status - Unit 3 During the inspection, the Humboldt Bay Power Plant (HBPP), Unit 3, was being decommissioned by the licensee in accordance with commitments made in its Post Shutdown Decommissioning Activities Report, dated June 30, 2009. The licensee is in the process of analyzing the feasibility and cost of removing subsurface structures as part of the decommissioning process. A contracted study will begin in the near future and will be the subject of a future inspection 1 Safety Reviews, Design Changes, and Modifications (37801)
1.1 Inspection Scope The inspector evaluated whether the licensees conduct of safety reviews, design changes, and modifications were in accordance with license and regulatory requirements.
1.2 Observations The inspector reviewed on-site training (Maintaining the HBPP Licensing Basis)
that is conducted in part to ensure that the licensing basis for the HBPP is maintained current and accurate. This training is aimed at screening that is conducted by qualified workers to evaluate the impact of changes in equipment, processes, or procedures on the licensing basis. Licensee terminology for this activity is Licensing Basis Impact Evaluation (LBIE) screening (HBAP C-19, Licensing Basis Impact Evaluation), a screening process that addresses all of the HBPP licensing bases on one form. Objectives of the training were to allow the worker to first identify and locate documents that make up the HBPP Licensing Basis, relate this screening to the regulatory requirements of 10 CFR 50.59 and 10 CFR 72.48, and describe the various processes that are employed to make changes to the HBPP Licensing Basis Documents. Completion of the training, which includes a written examination, qualifies a worker as one who can prepare an LBIE screen. Of note is the fact, as presented in the training, that all LBIE screens are reviewed for accuracy and that only individuals designated in writing by the plant manager are authorized as reviewers of LBIE screens. The inspector reviewed examples where a proposed change was initially screened as not having an impact on the licensing basis, screened out, but in review was found to have a significant impact and therefore should have been screened in and subjected to further review. As an example, a change was proposed to the hot shop exhaust. During a thorough review of related technical and licensing issues, the reviewer of the initial hot shop exhaust change screen noted that the proposed change represented a potentially adverse change to the ventilation system design. It eliminated a discharge through an approximately 50 foot tall stack, changing the discharge from one at an elevated level to one at ground level. The height of the plant stack is a mitigating credit in some accident scenarios and could impact the worker, public, and environment. The reviewer revised the initial screening document to ensure that any further documentation of impact on the licensing basis would be in compliance with regulatory and license requirements.
-4- Enclosure
As noted in the previous inspection report (IR 0500-133/12-007), a licensee Quality Verification Audit of the site Emergency Plan (2011 Emergency Plan Audit dated January 18, 2012) identified 13 deficiencies. Condition Reports (SAPNs) were generated for each deficiency and tracked in the licensees corrective action program. A vendor was selected who completed revision of the Emergency Plan (EP), Emergency Plan Implementing Procedures (EPIP), and Emergency Operating Procedures (EOP). The HBPP Plant Staff Review Committee approved the revisions on February 28, 2012. Training material was also revised and following approval of the EP, EPIP, and EOP by the Plant Safety Review Committee, training for staff and contractors commenced on February 29, 2012. The inspector noted that only one corrective action, dealing with documentation of the distribution of informational copies, remained to be completed as of the date of the inspection.
The licensee supplied a Quality Verification Audit of the HBPP Fire Protection and Loss Prevention Program that received final approval on March 8, 2012.
The scope of this audit was to verify effectiveness of the HBPP Fire Protection Program for Unit 3 and the Independent Spent Fuel Storage Installation (ISFSI).
Regarding the ISFSI, the audit self-identified two areas of concern: first, compliance with Final Safety Analysis Report (FSAR) limits of combustible material within the ISFSI fenced area; and second, control of vegetation growth near the ISFSI. Corrective actions to address these areas have been identified and the inspector verified that they are being implemented. For Unit 3, the audit found the Fire Protection Program to comply with applicable regulatory guidance and National Fire Protection Agency (NFPA) standards. However, implementation of the program was self-identified to be deficient in 15 areas.
Condition reports were generated to track corrective actions and a Technical Review Group was convened to evaluate the impact of the issues. Follow up on closure of corrective actions will be a subject of a future inspection.
1.3 Conclusions The licensee conducted safety reviews, design changes, and modifications in accordance with license and regulatory requirements.
2 Decommissioning Performance and Status Review (71801)
2.1 Inspection Scope The inspector evaluated whether the licensee and its contracted workforce were conducting decommissioning activities in accordance with license and regulatory requirements.
2.2 Observations The licensees project team continues to work to determine the end state of decommissioning and key assumptions and costs associated with various options.
-5- Enclosure
As noted in a previous inspection report (IR 050-00133/12-07) on Wednesday February 15, 2012, the facility experienced a near miss safety event when a live 480 volt line was penetrated by a worker. The electrician did not notice any electrical shock though this was a near miss to a potentially fatal event. An investigation was initiated and a condition report issued to document the event.
Since the previous inspection a Technical Review Group was formed to investigate the event and meetings have begun. Results of the efforts of the Technical Review Group will be reviewed in a future inspection.
The inspector observed ongoing work in the reactor building in preparation for the lift of the chimney from the reactor vessel and its transfer to the spent fuel pool where at a later date the chimney will be sectioned prior to shipment for disposal. Workers were observed to be in compliance with requirements of the applicable Radiation Work Permit (RWP) specifically written for the chimney transfer (RWP 20120110, start date of March 20, 2012, Title: Transfer the Reactor Vessel Chimney from the RPV (Reactor Pressure Vessel) to the SFP (Spent Fuel Pool)). Radiological postings in the area where the transfer was to occur were clearly visible and met the requirements of 10 CFR Part 20. The licensee had calculated potential direct radiation and airborne levels for various contingencies and had adequately prepared the area should these actions have proven to be needed. During site tours, the inspector measured ambient gamma exposure levels with a Ludlum Model 2401-EC2 survey meter (NRC Serial Number 257911, calibration due 01/09/2013). No areas were found that were inconsistent with postings.
2.3 Conclusions The licensee conducted decommissioning activities in accordance with license and regulatory requirements. Radiation postings and boundaries were maintained in accordance with regulatory requirements. Ongoing work was conducted following applicable procedures and in accordance with license and regulatory requirements.
3 Occupational Exposure During SAFSTOR and DECON (83100)
3.1 Inspection Scope The inspector evaluated the licensees program for monitoring and tracking occupational exposure of occupational workers to ensure that the program was in accordance with license and regulatory requirements.
3.2 Observations Based on data supplied by the licensee, the inspector noted that the actual personnel exposures through the end of February 2012 of 15.4 Man-Rem compares favorably to an estimated level of 19.0 Man-Rem. Licensee estimates of exposure beginning in March 2012 and continuing through November 2012, show an increase in level to approximately 65 Man-Rem due to tasks, such as reactor vessel internals removal and liquid radioactive waste tank removal, that are characterized by higher beta-gamma levels than have been experienced to date.
-6- Enclosure
The removal of the chimney from the reactor vessel and transfer to the spent fuel pool, where the chimney will be sectioned prior to shipment to a waste burial site, is one of the evolutions where the potential for elevated exposures exists.
Because of the exposure potential, the licensee analyzed the radiological impact of both normal and abnormal processes for movement of the chimney. To maintain exposures ALARA, the licensee allowed only three individuals to be present in the refueling building during the transfer. These individuals included a radiation protection technician, the crane operator, and a rigger. These individuals were located behind a shield approximately 30 feet from the location where the chimney would emerge upon removal from the reactor vessel. Use of cameras, laser positioning devices, remote radiation detection systems, and video displays were emphasized. Real time video feed was provided to monitors where senior staff were located to include an area for viewing by the inspector.
The inspector was also able to view outputs from several continuous air monitoring systems. Movement of the chimney was controlled remotely. To minimize the generation of airborne radioactivity, the chimney was fogged with a fixative spray while being removed from the reactor vessel. During the evolution, radiation protection personnel monitored dose rates and controlled access as necessary.
The removal and movement of the chimney was accomplished without incident.
Pre-job calculation of anticipated exposure of personnel based on conservative assumptions estimated an exposure for normal transfer of 7 mrem. Measured values of actual exposure based on electronic dosimeter readings were 3.3 mrem, in reasonable agreement with pre-job calculations. Soon after the lift, derived air concentration (DAC) levels in the refueling building reached 2.5 DAC and continued to rise, reaching a peak of approximately 5 DAC before leveling off. The licensee postponed sectioning of the chimney to allow for decrease in the airborne level in the refueling building.
The inspector reviewed initial training of radiation protection technicians to include job performance measures. The program follows a systematic approach to training and dedicates time to instrument usage, including limitations of instrument types. The emphasis on proper choice and use of instruments is appropriate as there are increases expected in external exposure due to isotopes emitting beta and gamma radiation. The inspector discussed instrument usage with radiation protection technicians who demonstrated an appropriate level of knowledge. The technicians were also aware of calibration requirements and knew that instrument calibration was tracked in a database to ensure that only instruments with current calibration were utilized in the field. The inspector reviewed the instrument database. The listing of instruments, their location, and the required calibration dates are color coded to allow for quick verification that calibration is current. The inspector verified that on the required calibration date the database redlines an instrument so that it is removed from service. The inspector also reviewed processes used to update previously qualified junior and senior technicians to ensure that they remain current on new instrumentation, changes in procedures, and lessons learned. The use of formal training sessions, required reading, and safety meeting tailboards was noted. The inspector observed conduct of training in daily morning meetings and reviewed documentation of past training sessions.
-7- Enclosure
3.3 Conclusions The inspector reviewed techniques for control of occupational exposure during ongoing work, especially during the chimney lift and transfer evolution. Exposure controls were implemented as described in applicable procedures. The inspector also reviewed the licensees program for assessing internal exposures and noted that the program met regulatory requirements.
4 Radioactive Waste Treatment and Effluent and Environmental Monitoring (84750)
4.1 Inspection Scope The inspector reviewed effluent and environmental monitoring programs to determine whether the licensee conducted these efforts in accordance with license and regulatory requirements.
4.2 Observations The Humboldt Bay Power Plant site is very limited in size, thus the licensee has found it necessary to survey decontaminated and decommissioned areas and then backfill or pave over areas to allow for decommissioning activities, such as storage of materials. Prior to backfilling or paving, the licensee characterizes the area through use of data collected during walkover gamma measurements and soil sampling. The inspector reviewed the licensee surveys and found them to be in accordance with their plan and procedures. The inspector also reviewed the licensee process for soil sample tracking, preparation, and analysis (C&RPD-3, Final Status Survey Sample Preparation, Rev 0). The licensee utilizes a bar code system to minimize data transfer errors during collection and analysis.
Selected licensee soil samples from a recent survey were forwarded to the NRCs contracted laboratory, Oak Ridge Institute for Science and Education (ORISE) in Oak Ridge, TN, for analysis, interpretation, and comparison of results. Sample analysis at Oak Ridge will be performed in accordance with ORISE Procedures. Results of this laboratory inter-comparison will be documented in a future ORISE report which will be made publicly available in NRCs Agencywide Documents Access & Management System (ADAMS).
As a follow up to a previous inspection (IR 050-00133/11-08), the inspector reviewed the status of the Radioactive Liquid Effluent Monitor System (RLEMS).
Updating of this system, which monitors radioactivity in liquid discharges prior to release to the environment, involves installation of a new detection system and a change in system location. The modification replaces the detector, preamplifier, and cable between the preamplifier and ratemeter. During the earlier inspection, it was noted that full acceptance of the RLEMS had not been completed due to the fact that the system frequently tripped due to an unknown cause. To restore system operation, a manual reset is required. When the system trips, liquid discharge to the environment is not permitted so there are no unmonitored discharges. Further investigation by the licensee determined that HBPP has experienced a number of short power outages or voltage reductions that have adversely effected some key equipment, including the RLEMS system. The uninterruptable power supply (UPS) system supporting the RLEMS could not-8- Enclosure
maintain system operation as desired, resulting in unnecessary trips requiring operator action to restore system functions. The licensee is in the process of replacing the current switching UPS system with a full double conversion in line UPS that has no transfer time and therefore will maintain power to circuits during transitions from the normal feed to battery based feed, avoiding spurious trips.
Operation of the improved RLEMS system will be reviewed during a future inspection.
During site tours, the inspector noted that silting of the discharge canal continues. Licensee data based on GPS system measurements verifies that the amount of tidal volume available for dilution of treated, monitored effluents from the liquid radwaste treatment system continues to decrease. If silt buildup continues, conservative dilution factors utilized in off-site dose calculations will need to be reduced. The next series of measurements is scheduled for April 2012 and, based on results of these measurements, the Off-Site Dose Calculation Manual (ODCM) will be revised appropriately. Data applicable to silting of the discharge canal will be reviewed in a future inspection.
4.3 Conclusions The licensee conducted effluent and environmental monitoring in accordance with license and regulatory requirements.
5 Solid Radioactive Waste Management and Transportation of Radioactive Materials (86750)
5.1 Inspection Scope The inspector reviewed the licensees programs for radioactive waste management and transportation of material for disposal.
5.2 Observations and Findings The volume of waste shipped off-site has decreased following the completion of the decommissioning of Units 1 and 2. The major destinations for radioactive waste shipments from the site are the Energy Solutions site in Clive, Utah, a site accepting Class A waste material, and the US Ecology site in Grand View, Idaho, a Resource Conservation and Recovery Act (RCRA) site that accepts material containing very low levels of radioactivity. The inspector selected a set of shipping papers for each site and reviewed the packages for compliance. The inspector noted that the papers contained a basic description of the shipment, including a proper shipping name, hazard class, and U.N. identification number.
Also included was a 24-hour emergency response telephone number which the inspector verified to be located in the ISFSI Primary Alarm Station, a location which is staffed by Security personnel on a 24-hour basis. The licensee noted that, when a shipment is in progress, the Primary Alarm Station is provided a copy of the shipping documentation in case they are contacted by state or federal agencies during a shipment. Licensee personnel noted that states have utilized the contact number to verify shipment content. The shipping papers also listed the number and type of packages and named each radionuclide. Where appropriate, activity levels in storage installation units were included. The-9- Enclosure
packages included a shippers certification and signature. The inspector verified that only three on-site employees have been authorized by the Radiation Protection Manager to sign the certification documents. The licensee utilizes checklists to ensure compliance with requirements (Fossil Decommissioning Radwaste Shipping Desk Guide, Rev. 0 and HBPP Radioactive Materials Shipment Check-off List, Attachment 10.6 to RCP-6P, Rev. 12A).
5.3 Conclusions The licensee conducted radioactive waste management and transportation activities in accordance with license and regulatory requirements.
6 Exit Meeting The inspector reviewed the scope and preliminary findings of the inspection during an exit meeting that was conducted at the conclusion of the onsite inspection on March 25, 2012. The licensee did not identify as proprietary any information provided to, or reviewed, by the inspector.
- 10 - Enclosure
SUPPLEMENTAL INSPECTION INFORMATION PARTIAL LIST OF PERSONS CONTACTED J. Albers, Radiation Protection Manager D. Anderson, Count Room Supervisor B. Arroyo, Site Services Manager A. Berry, Radwaste Supervisor W. Barley, RP Consultant and FSS Supervisor C. Caldwell, Area Supervisor M. Celletti, Training Manager J. Chadwick, RP Engineering Supervisor, ALARA A. Cordone, Decommissioning Projects Superintendent G. Field, RP Training G. Frank, RP Instrument Supervisor J. Griffin, Licensing Termination Manager L. Hardwick, SAFSTOR Supervisor S. Jones, QA Supervisor S. McDonald, Safety/IH Department Supervisor K. Rod, Decommissioning Manager S. Schlerf, Radiation Protection Forman L. Sharp, Director and Plant Manager M. Smith, Engineering Manager R. Snyder, RW/Transportation Manager D. Sokolsky, Licensing Supervisor M. Tuse, QV Supervisor INSPECTION PROCEDURES USED IP 37801 Safety Reviews, Design Changes and Modifications at Permanently Shutdown Reactors IP 71801 Decommissioning Performance and Status Review at Permanently Shutdown Reactors IP 83100 Occupational Exposure During SAFSTOR and DECON IP 84750 Radioactive Waste Treatment and Effluent and Environmental Monitoring IP 86750 Solid Waste Management and Transportation ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed None Attachment
Discussed None LIST OF ACRONYMS ALARA as low as reasonably achievable CFR Code of Federal Regulations DAC derived air concentration EP Emergency Plan EOP Emergency Operating Procedures EPIP Emergency Plan Implementing Procedures HBPP Humboldt Bay Power Plant IP NRC Inspection Procedure ISFSI independent spent fuel storage installation LBIE Licensing Basis Impact Evaluation NFPA National Fire Protection Agency ODCM Offsite Dose Calculation Manual RCRA Resource Conservation and Recovery Act RLEMS radioactive liquid effluent monitor system RWP radiation work permit SFP spent fuel pool UPS uninterruptable power supply-2- Attachment