IR 05000133/2016003

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NRC Inspection Report 050-00133/2016-003
ML16243A393
Person / Time
Site: Humboldt Bay
Issue date: 08/31/2016
From: Whitten J
Division of Nuclear Materials Safety IV
To: Halpin E
Pacific Gas & Electric Co
G. Schlapper
References
IR 2016003
Download: ML16243A393 (15)


Text

ust 31, 2016

SUBJECT:

NRC INSPECTION REPORT 050-00133/2016-003

Dear Mr. Halpin:

On August 9-11, 2016, the U.S Nuclear Regulatory Commission (NRC) conducted an inspection at the permanently shut down Humboldt Bay Power Plant, Unit 3 facility, near Eureka, California. The purpose of the inspection was to determine whether decommissioning activities were being conducted safely and in compliance with NRC requirements. At the conclusion of on-site inspection, August 11, 2016, the results were discussed with members of your staff.

During this inspection, NRC staff examined activities conducted under your licenses as they relate to public health and safety to confirm compliance with the Commissions rules and regulations, and with the conditions of your license(s). Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel. The enclosed report presents the results of this inspection. No violations were identified, and no response to this letter is required.

In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, 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 document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary information so that it can be made available to the Public without redaction. If you have any questions concerning this inspection, please contact Dr. Gerald Schlapper, Health Physicist, at 817-200-1273, or the undersigned at 817-200-1197.

Sincerely,

/RA LEBrookhart Acting for/

Jack E. Whitten, Chief Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety Docket No: 050-00133 License No: DPR-7 Enclosure:

NRC Inspection Report 050-00133/2016-003 Attachment: Supplemental Information

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 050-00133 Licenses: DPR-7 Report: 050-00133/2016-003 Licensee: Pacific Gas & Electric Company Facility: Humboldt Bay Power Plant, Unit 3 Location: 1000 King Salmon Avenue Eureka, California 95503 Dates: August 9-11, 2016 Inspectors: Gerald A. Schlapper, PhD, CHP Health Physicist Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety Donald L. Stearns, Health Physicist Fuel Cycle and Decommissioning Branch Division of Nuclear Material Safety Approved By: Jack E. Whitten, Chief Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety Enclosure

EXECUTIVE SUMMARY

Humboldt Bay Power Plant, Unit 3

NRC Inspection Report 050-00133/2016-003 This U.S. Nuclear Regulatory Commission (NRC) 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.

Decommissioning Performance and Status Review

  • The inspectors observed various decommissioning activities in progress. The inspectors concluded that the licensee was conducting decommissioning in accordance with the general guidance provided in the Post-Shutdown Decommissioning Activities Report.

During the inspection the licensee was performing final status surveys of selected areas.

NRC Contractor, Oak Ridge Associated Universities, with oversight by the NRC inspectors, performed verification surveys of the same areas. The licensees work was being conducted with an emphasis on industrial and radiological safety. (Section 1.2.a)

  • The licensee has shifted from self-performance of high risk activities to oversight of a civil works project. While there were lessons learned during the changeover, the contractor has applied the lessons learned and showed a high level of confidence in completing projects on time and within budget. (Section 1.2.b)

Organization, Management, and Cost

  • The licensee continues to implement a program of safety reviews, design changes and modifications. As required by the Quality Assurance Program, the licensee completed an independent management review. (Section 2.2)

Solid Radioactive Waste Management and Transportation of Radioactive Materials

  • The licensee was characterizing, packaging, and shipping wastes in accordance with procedural requirements and restrictions established in requests previously approved by the NRC. (Section 3.2)

Maintenance and Surveillance

  • The licensee was conducting a program for maintenance and calibration of portable radiation survey instruments and the Guardian System for monitoring radiological contaminants in accordance with applicable procedures, license, and regulatory requirements. (Section 4.2)

REPORT DETAILS

Site Status At the time of the inspection, the licensee continued to decommission the site in accordance with the general guidance provided in the Post-Shutdown Decommissioning Activities Report (PSDAR) dated July 19, 2013, (ADAMS Accession No. ML13213A160), Revision 11 to the Defueled Safety Analysis Report (DSAR) (ML16029A508), and Revision 33 to the Humboldt Bay Power Plant (HBPP) Quality Assurance Plan (QAP) (ML16029A508). The decommissioning work in progress included completion of and testing of the subsurface cutter soil mixture (CSM) wall, movement of the excavated soil to the former discharge canal, removal of potentially contaminated soil, concrete, piping, preparation for decommissioning of the intake canal, and continued demolition of the refuel building.

The CSM wall was completed in June 2016. Some panels in the outer ring were reworked to ensure they reached to the clay layer. The licensee plans to begin excavating the caisson structure in the last quarter of 2016. In May, the contractor completed demolition of the low level waste and solid radioactive waste buildings. Demolition of the high level storage vault and liquid radioactive waste building was completed in July. Other projects planned for 2016 include final demolition of the refueling building and remediation of the intake canal. After completion of site decommissioning, the licensee plans to conduct final status surveys and site restoration work.

The licensee currently plans to complete all field work by 2018.

A License Termination Plan (LTP) was submitted to the NRC on May 3, 2013 (ML13130A009, ML13130A011). To address requests for additional information the licensee submitted LTP Revision 1 on August 13, 2014 (ML14246A157, ML14246A158, and ML14246A159). The plan defined the end state of the site, refined decommissioning cost estimates, and provided a detailed baseline for cost and schedule considerations. On May 4, 2016, the NRC issued Amendment No. 45 to Facility Operating License No. DPR-7 (ML15090A339). The amendment revised the Humboldt Bay Unit 3 License to add License Condition 2.C(5) which incorporated the NRC approved LTP and specified limits on the changes the licensee is allowed to make to the approved LTP without prior NRC approval.

1. Decommissioning Performance and Status Review (71801)

.1 Inspection Scope

The inspectors evaluated whether the licensee and its contracted workforce were conducting decommissioning activities in accordance with license and regulatory requirements.

.2 Observations and Findings

a. Completion of the Subsurface CSM Wall The inspectors noted completion on June 16, 2016, of one of the critical path elements in the overall decommissioning effort, construction of the CSM wall. After monitoring for potential radioactive contaminants, the resultant excavated materials were transferred to the discharge canal for future use as backfill material. Materials not meeting the criteria for reuse on site are packaged and shipped to the appropriate waste site.

The CSM wall consists of five concentric rings of various depth to allow for excavation to a depth of approximately 95 feet. The innermost ring is approximately 110 feet inside diameter and 105 feet deep. Succeeding rings increase depth by approximately 4 foot per ring. The outermost layer of the ring (denoted as the E ring) penetrates into an underlying clay layer at approximately 175 feet depth. Individual panels of the wall are 3 feet thick and 9 feet long. The total thickness of the wall is approximately 13 feet. Based on observations and discussions with staff, the inspectors determined that the licensee had conducted work in accordance with work plan requirements.

Due to the potential for some water intrusion into the area surrounded by the CSM wall, the contractor installed four dewatering wells. The wells will pump effluent to the ground water treatment system (GWTS) for characterization and treatment followed by discharge to Humboldt Bay. Current measurements reflect a water intrusion rate of approximately 15 to 20 gallons per minute, which is within design specifications.

After the CSM wall has cured, the contractor is planning to begin the excavation work in the last quarter of 2016. Access control will be implemented to limit entry into the area.

Radiological controls to include air monitoring, high-efficiency particulate air (HEPA)ventilation, and area thermoluminescence dosimeter (TLD) badge placement will be initiated as appropriate for the anticipated levels of radioactivity that will be encountered in the soils and construction materials.

The inspectors reviewed the licensees procedures for ensuring that excavated materials from various on-site locations were not contaminated with radioactive and non-radioactive contaminants and were thus acceptable for use on-site as backfill. The licensee and its contractor implemented several controls including collection of samples and bulk container monitoring. The inspectors verified that the licensee was ensuring that concentrations of any contaminants were below the soil cleanup derived concentration guideline levels in use by the licensee. The bulk sampling program consists of surveying truckloads of excavated material using the onsite GUARDIAN detector system. A truck/trailer scan was conducted just prior to transfer of the spoils to the onsite discharge canal. Further discussion of the use of this system is presented in a later section of this report.

During the inspection the licensee conducted final status surveys (FSS) of selected locations utilizing gamma detectors for walkovers of the area combined with collection of soil samples. Concurrent with licensee activity, Oak Ridge Associated Universities (ORAU) under contract to NRC conducted confirmatory survey activities based on an NRC approved project specific plan. The confirmatory surveys are to assess and determine the adequacy of the licensees FSS design, implementation, and documentation for demonstrating compliance with release criteria for the site. The on-site NRC inspectors provided oversight of the survey efforts and provided consultation to the ORAU field team leader regarding any potential changes to the survey procedures. Results of the ORAU confirmatory surveys will be published in a separate report to be issued once review of the gamma walkover data and soil sample analysis is completed.

The inspectors reviewed data applicable to the exposure pathways of airborne and direct radiation. The airborne pathway exposures are based on measurements at five on-site locations and one off-site location. Direct radiation exposure levels are measured using TLD monitoring stations. These include a minimum of eight on-site locations, four off-site locations, and one off-site control location. Data presented indicated that levels were essentially at background levels, verifying that the licensees techniques to minimize exposure to personnel on-site and off-site were appropriate.

b. Civil works project status The contractor for the civil works portion of the decommissioning, Chicago Bridge and Iron (CB&I), continues to prepare the remaining portions of site buildings for demolition. From 2012 through 2015, the licensee shifted from self-performance of high risk activities to oversight of the civil works projects. The licensee noted that the civil works project is over fifty percent complete after two and one-half years of work execution. Discussions with the licensee and the civil works contractor noted that alternative approaches to decommissioning proposed by CB&I enhanced completion of work and resulted in a projected contract completion date of fall 2018 rather than an earlier estimate of spring 2019. Targets for completion in 2016 were completing demolition of the refuel building in August, completion of discharge canal work in October, starting work on the caisson excavation in August and completion of work on the intake canal during November.

The site continues to face challenges of site congestion, contaminated underground systems and utilities, frequent adverse weather, soil and water management, below grade obstructions, limited site access, and proximity to the surrounding community and the active Humboldt Bay Power Generating Station (HBGS).

.3 Conclusions

The inspectors observed various decommissioning activities in progress. The inspectors concluded that the licensee was conducting decommissioning in accordance with the general guidance provided in the PSDAR, DSAR and HBPP QAP. The work was being conducted in accordance with approved work plans and with an emphasis on industrial and radiation safety.

2. Organization, Management and Costs (36801)

.1 Inspection Scope

The inspectors reviewed the licensees implementation of its safety review, design change, and modification program as required by 10 CFR Part 50, license, and procedural requirements. The licensees implementation of these reviews rests primarily on action of the Plant Staff Review Committee (PSRC) and an independent management review. The inspectors noted that the PSRC committee had not met during the period following the previous inspection conducted in April 2016 but that an independent management review was completed.

.2 Observations and Findings

Many decommissioning activities involve quality-related structures, systems, and components (SSC). These activities are governed by the HBPP QAP and are therefore subject to independent quality assurance audits. Activities audited included radiation protection controls, effluent monitoring, radioactive waste shipping, site characterizations, fire loss protection and prevention program, Emergency Plan, Security Plan, and Off-site Dose Calculation Manual (OSDCM). The QAP includes a requirement for an Independent Management Review (IMR) function, the implementation of which is through Procedure HBAP A-6, effective September 4, 2014. The purpose of the independent management review was to assess the effectiveness of the HB Quality Assurance Program. The procedure noted that the Chief Nuclear Officer is responsible for designating the reviewer(s) to assess the effectiveness of the QAP and other appropriate oversight activities at the site. The licensee is committed to conducting a review at a minimum of every two years.

By written memo signed by the Chief Nuclear Officer, dated May 13, 2016, Mr. Joseph Bourassa was appointed to conduct the independent management review. The NRC inspectors reviewed his qualifications and noted that he fully satisfied requirements set for the position based on his over 30 years of experience in nuclear facility construction, operation, independent assessment, and decommissioning. He had previously served as a member of the Humboldt Bay Nuclear Power Plant Safety Oversight Committee (NSOC). The IMR was completed on June 19, 2016 and thereby met timeliness requirements.

The NRC inspectors reviewed the content of the IMR that addressed the quality activities performed at the Humboldt Bay Power Plant and the Humboldt Bay Independent Spent Fuel Storage Installation (ISFSI). The License Termination Plan (LTP) Quality Assurance Program described in Section 5.8 of the LTP was not in the scope of the IMR since it was not included in the HB QA Plan but the inspectors noted that some elements of the LTP QA Plan were included as part of the IMR. The review concluded that implementation of the QA Plan and associated controls for Unit 3 and the ISFSI were acceptable but additional management focus was necessary to continue required refinement of the efforts. The report stated that though separation of the QA Programs for Unit 3 and the ISFSI was appropriate and that efforts received management focus and attention during transition there were areas requiring additional attention to minimize vulnerabilities.

The NRC inspectors reviewed a May 10, 2016 report that summarized a program to evaluate alternate means and methods to further reduce the risk of a traffic accident or incident associated with the preparation, loading, and transportation of solid waste from HBPP. The Solid Waste Efficiency and Expediency Test Shipments (SWEETS) proposal utilized a combination of truck and rail transport to ship solid waste from HBPP to authorized burial sites. Prior to this study, waste was loaded into intermodal containers and transported by truck to a licensed disposal facility, one operated by US Ecology in Grand View, Idaho and the other operated by Energy Solutions in Clive, Utah. Once the intermodal containers reached these facilities, they were unloaded and transported back by truck to HBPP to begin another round of shipping. The licensee estimated that to the end of the decommissioning project approximately 2700 shipments would be required.

The SWEETS proposal shipped IP-1 rated bags that were loaded into designated dump trucks and transported to a rail facility in Redding, California. Once in Redding, the bags were placed into railcars for transport to the Waste Control Specialists (WCS) disposal facility in Andrews, Texas. The program proposal was a joint effort between the licensee and the disposal contractor. The study noted that transportation by rail is advantageous from a safety standpoint, quoting statistics that on average the fatality rate of the truck transportation industry was 7 times higher and the injury rate was 15 times higher than rail transport. Based on results of the testing program, the licensee added the WCS site as an alternative waste disposal location.

.3 Conclusions

The licensee implemented its program of safety reviews, design changes and modifications in accordance with requirements of 10 CFR Part 50, license, and procedural requirements.

A program for the Independent Management Review function had been established and the required review was completed in a timely manner. The licensee continues to perform analysis of risk and risk reduction.

3. Solid Radioactive Waste Management and Transportation of Radioactive Materials

(86750)

.1 Inspection Scope

The inspectors reviewed documentation associated with shipments of material to the licensees respective burial sites. The shipments included solid waste shipments of exempt material to a site approved for Resource Conservation and Recovery Act (RCRA)waste in Idaho, low specific activity solid waste shipment to a Utah burial site, and shipments of low specific activity waste to Waste Control Specialists (WCS) in Texas. The review included documentation required by Department of Transportation (DOT)regulations, and documentation of waste classification required by 10 CFR Part 20.

.2 Observations

To ensure compliance with applicable NRC and DOT regulations, the licensee continued to utilize a shipping compliance checklist. The checklist required that the licensee have documentation on file that certified that any container used -met regulatory qualifications and that vendor provided procedures for use of the container were followed. The documentation included information that the manifest was consistent with the approved waste profile. Other documents supplied in the package indicated that the containers had been inspected by the licensee and were determined by the NRC inspectors to be in compliance with DOT packaging requirements. Radiation/contamination survey data sheets verified compliance with applicable limits outlined in 10 CFR 71.47. Emergency response information was supplied with all shipments. Prior to departure, a signature by the licensee indicated that all documents associated with the shipment had been completed in accordance with licensee procedures and that the material was packaged, characterized, classified, marked, labeled, placarded, and transported in accordance with regulatory requirements of the NRC and DOT. An NRC review of documents for selected shipments indicated that license and DOT regulatory requirements were met.

The inspectors reviewed the licensees management of exemption wastes shipped to a facility in Idaho. The NRC granted the licensee three exemptions under alternate disposal provisions allowed under 10 CFR 20.2002. As of August 9, 2016, the licensee had shipped a total of 740,926 cubic feet (33.7 percent of allowed volume) under exemptions 1 and 2, and a total of 31,519 cubic feet (31.52 percent of allowed volume) under exemption 3.

The inspector also reviewed documentation for two recently completed shipments for compliance with procedure requirements and NRC regulations. The review included shipments to Energy Solutions and Waste Control Specialists. The inspector observed licensee staff personnel load the material, perform surveys of the transport containers, and complete shipment documentation.

From January 1, 2016, through August 9, 2016, the licensee made 379 shipments to US Ecology in Idaho under exemptions 1 and 2, 47 shipments to Energy Solutions in Clive, Utah, 1 shipment to Permafix in Richland, Washington, and 37 shipments to WCS in Andrews, Texas, for a total of 464 shipments. There were no shipments under exemption 3 during this time period.

.3 Conclusions

The licensees program for transportation of solid waste material for off-site burial was being performed in accordance with license and regulatory requirements.

4. Maintenance and Surveillance (62801)

.1 Inspection Scope

The inspectors reviewed calibration and maintenance of portable radiation survey instruments.

.2 Observations

The licensee continued to require use of portable radiation survey instrumentation. The inspectors observed the staging, calibration, and use of instruments.

The licensee utilized a color coding system to track calibration due dates of each instrument. For example, green indicated the instrument was calibrated and available for use, yellow indicated the instrument was within 30 days of the calibration due date, and red indicated the instrument was past due for calibration or unavailable for use.

The licensee continued calibrating its count-rate instrumentation at the site, but sends dose-rate instrumentation to either a vendor licensed to calibrate instruments or to the Diablo Canyon Nuclear Station. The inspectors reviewed the licensees procedures for calibration of count-rate instruments and calibration of the MGPI Alpha Continuous Air Monitor. The inspectors determined that the calibration methodologies were consistent with American National Standards Institute guidance (ANSI). The licensee continues to calibrate two personnel contamination monitors (PCM) and one small article monitor (SAM). The inspectors reviewed the licensees procedures for calibration of the PCM and SAM monitors. The inspector determined that the methodologies utilized were consistent with ANSI guidance.

Material excavated from the site was monitored for radioactive contaminants to determine if the material was acceptable for re-use onsite, or if it must be shipped to an offsite burial site for disposal. The excavated material was loaded in dump trucks and monitored via a system (GUARDIAN) to measure the radiological contaminants. If the material had very low levels of contaminants, the material was placed in a staging area for reuse. If the levels of contaminants were above a specific level, the material was placed in a temporary covered area and was packaged for shipment to a burial site. Excavation of the material surrounding the reactor caisson will significantly increase the use of the GUARDIAN system. A second GUARDIAN system was currently being installed adjacent to the first GUARDIAN system. The second system will incorporate a total of six detectors verses four detectors in the current system and may result in shorter monitoring times for each load of material. The new system was expected to be operational by the end of August, 2016.

The inspectors observed ten trucks of material processed through the GUARDIAN system and observed the operation of that system. Daily checks were performed on the detectors by the licensee to ensure performance was consistent with the performance at the time of system calibration. Control charts were utilized to track the daily performance. The inspectors also discussed the installation, setup, and calibration of the second GUARDIAN system. The technicians responsible for setup and operation of the two systems had sufficient knowledge and experience to perform all required tasks.

.3 Conclusions

The inspectors noted that the licensee programs for maintenance and calibration of portable radiation survey instruments and use of the Guardian System for bulk sample measurement were in compliance with applicable procedures and regulatory requirements. The inspectors also checked selected instruments and noted that the instruments in use were within current calibration dates.

5. Exit Meeting

The inspectors presented the inspection results to the licensees representatives at the conclusion of the onsite inspection on August 11, 2016. The licensee did not identify any information reviewed by the inspectors as proprietary.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Chadwick, ALARA Supervisor
V. Cornell, Site Closure Engineer
B. Costa, ISFSI Licensing
P. Coutts, Program Manager, CB&I
E. Kahler, Engineering Manager
M. King, Project Engineer
D. LeBouef, Deputy Program Manager, CB&I
W. Parish, RP/FSS Engineer
K. Rod, Decommissioning Manager
K. Rowberry, Site Closure Specialist
J. Salmon, Environmental Manager
L. Sharp, Director and Plant Manager
D. Sokolsky, Licensing

INSPECTION PROCEDURES USED

IP 37801 Safety Reviews, Design Changes and Modifications at Permanently Shutdown Reactors

IP 62801 Maintenance and Surveillance at Permanently Shutdown Reactors

IP 71801 Decommissioning Performance and Status Review at Permanently Shutdown

Reactors

IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Closed

None

Discussed

None

LIST OF ACRONYMS

ADAMS Agencywide Documents Access and Management System

ALARA As Low As Reasonably Achievable

CAP corrective action program

CB&I Chicago Bridge and Iron

CFR Code of Federal Regulations

CSM cutter soil mix

DSAR Defueled Safety Analysis Report

FSAR Final Safety Analysis Report

GWTS ground water treatment system

HBGS Humboldt Bay Power Generating Station

HBPP Humboldt Bay Power Plant

IMR Independent Management Review

IP Inspection Procedure

ISFSI Independent Spent Fuel Storage Installation

LTP License Termination Plan

NRC U.S. Nuclear Regulatory Commission

NSOC Nuclear Safety Oversight Committee

PSRC Plant Staff Review Committee

PSDAR Post-Shutdown Decommissioning Activities Report

QAP Quality Assurance Plan

SSC Structures, Systems and Components

SWEETS Solid Waste Efficiency and Expediency Test Shipments

TLD thermoluminescence dosimeter

WCS Waste Control Specialists

µR/hr micro Roentgens per hour

-2-

ML16243A393

SUNSI Review ADAMS Publicly Available Non-Sensitive Keyword:

By: GAS Yes No Non-Publicly Available Sensitive NRC-002

OFFICE RIV/DNMS:FCDB RIV/DNMS:FCDB C:FCDB

NAME GASchlapper DLStearns JEWhitten

SIGNATURE /RA/ /RA/ email /RA LEBrookhart Acting for/

DATE 8/31/16 8/31/16 8/31/16

Letter to Edward

D. Halpin from Jack E. Whitten dated August 31, 2016

SUBJECT: NRC INSPECTION REPORT 050-00133/2016-003

Distribution:

Kriss.Kennedy@nrc.gov, RA Scott.Morris@nrc.gov, DRA

Mark.Shaffer@nrc.gov, D:DNMS Linda.Howell@nrc.gov, DD:DNMS

Jack.Whitten@nrc.gov, C:FCDB Gerald.Schlapper@nrc.gov, FCDB

Eric.Simpson@nrc.gov, FCDB Robert.Evans@nrc.gov, FCDB

Lee.Brookhart@nrc.gov, FCDB Don.Stearns@nrc.gov, FCDB

John.Hickman@nrc.gov, NMSS Bruce.Watson@nrc.gov, NMSS

Matt.Meyer@nrc.gov, D:DSFM Jose.Cuadrado@nrc.gov, DSFM

Marisa.Herrera@nrc.gov, DRMA/FRMB Jeremey Bowen@nrc.gov, RIV/ETA: OEDO

Distribution:

Hossein Hamzehee Regulatory Services Mgr. Director, Radiologic Health Branch

Diablo Canyon & Humboldt Bay Power Plant State Department of Health Services

Pacific Gas and Electric Company P.O. Box 997414 (MS 7610)

P.O. Box 56 Sacramento, CA 95899-7474

Avila Beach, CA 93424

Gretchen Dumas, Esq.

Jennifer

L. Post, Esq. Public Utilities Commission State of California

Pacific Gas and Electric Company 5066 State Building

P.O. Box 7442 San Francisco, CA 94102

San Francisco, CA 94120

Director

Loren Sharp, Director and Plant Manager Energy Resources & Development Commission

Humboldt Bay Power Plant, PG&E 1516 9th Street

1000 King Salmon Avenue Sacramento, CA 95814

Eureka, CA 95505

Dr. Robert

B. Weisenmiller, Chair

Chairman California Energy Commission

Humboldt County Board of Supervisors 1516 Ninth Street (MS 34)

25 Fifth Street Sacramento, CA 95814

Eureka, CA 95501

Deputy Attorney General State of California

Law Office of Linda

J. Brown, Esq. 110 West A Street, Suite 700

999 5th Avenue, Suite 430 San Diego, CA 92101

San Rafael, CA 94901

Dr. Rich Ferguson, Energy Chair/Sierra Club California

Regional Radiation Representative 1100 11th Street, Suite 311

U.S. EPA Region IX Office Sacramento, CA 94814

Hawthorne Street

San Francisco, CA 94105 Redwood Alliance

P.O. Box 293

California Public Utilities Commission Arcata, CA 95521

505 Van Ness, Room 4102

San Francisco, CA 94102

Dr. James

F. Davis, State Geologist

Dept. of Conservation/Mines & Geology

801 K Street MS 12-30

Sacramento, CA 95814-3531