IR 05000133/2020001

NRC Inspection Report 05000133/2020-001 and 07200027/2020-001

ML20336A192
Person / Time
Site:	Humboldt Bay
Issue date:	12/01/2020
From:	Greg Warnick Division of Nuclear Materials Safety IV
To:	Welsch J Pacific Gas & Electric Co
References
IR 2020001
Download: ML20336A192 (20)

Text

December 1, 2020

SUBJECT:

Humboldt Bay Power Plant - NRC Inspection Report 05000133/2020-001 AND 07200027/2020-001

Dear Mr. Welsch:

This letter refers to the U.S. Nuclear Regulatory Commissions (NRCs) announced routine inspection conducted on November 3-4, 2020, of the Independent Spent Fuel Storage Installation (ISFSI) activities and the decommissioning activities associated with your Unit 3 facility. The NRC inspectors discussed the results of this inspection with Mrs. Paula Gerfen, Diablo Canyon Power Plant Site Vice President, and Mr. Eric Nelson, Director Nuclear Decommissioning and other members of your staff during the on-site final exit meeting conducted on November 4, 2020. The inspection results are documented in the enclosure to this letter.

The inspectors examined 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 inspections consisted of selected examination of procedures and representative records, observations of dry cask storage surveillance operations, and interviews with personnel. Specifically, the inspectors reviewed dry cask storage operations and compliance with the requirements specified in the site-specific ISFSI License SNM-2514 and associated Technical Specifications, the ISFSI Final Safety Analysis Report, and the regulations in Title 10 of the Code of Federal Regulations (CFR) Part 72 and Part 20. The decommissioning inspection focused on your corrective action program, decommissioning performance, organizational management, and radiological performance in accordance with the regulations in 10 CFR Part 50 and Part 20. The NRC inspectors did not identify any violations in either program area.

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 Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRCs Website 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 regarding this inspection report, please contact Lee Brookhart at 817-200-1549, or the undersigned at 817-200-1249.

Sincerely, Gregory G. Warnick, Chief Reactor Inspection Branch Division of Nuclear Materials Safety

Docket Nos.: 50-133;72-027 License Nos.: DPR-7; SNM-2514

Enclosure:

Inspection Report 05000133/2020-001 and 07200027/2020-001

Gregory G. Warnick Digitally signed by Gregory G. Warnick Date: 2020.12.01 12:25:46 -06'00'

ML20336A192 X SUNSI Review By: LEB ADAMS:

X Yes No Sensitive X Non-Sensitive Non-Publicly Available X Publicly Available Keyword NRC-002 OFFICE DNMS:RxIB DNMS:RxIB DNMS:MLDB DNMS:MLDB DNMS:RxIB NAME LEBrookhart CSmith REvans HGepford GGWarnick SIGNATUR

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DATE 11/19/2020 11/19/2020 11/20/2020 11/30/2020 12/1/2020

Enclosure

U.S. NUCLEAR REGULATORY COMMISSION REGION IV

Docket No.:

05000133; 07200027 License No.:

DPR-7; SNM-2514 Report No.:

05000133/2020-001 AND 07200027/2020-001 Enterprise Identifier:

I-2020-001-0159; I-2020-001-0101 Licensee:

Pacific Gas & Electric Company Humboldt Bay Power Plant Location:

Eureka, California 95503 Inspection Dates:

On-site: November 3-4, 2020 Exit Meeting Date:

November 4, 2020 Inspectors:

L. Brookhart, Senior ISFSI Inspector Reactor Inspection Branch Division of Nuclear Materials Safety, Region IV

C. Smith, Reactor/ISFSI Inspector Reactor Inspection Branch Division of Nuclear Materials Safety, Region IV

R. Evans, Senior Health Physicist Materials Licensing and Decommissioning Branch Division of Nuclear Materials Safety, Region IV

Approved By:

G. Warnick, Chief Reactor Inspection Branch Division of Nuclear Materials Safety, Region IV

EXECUTIVE SUMMARY

NRC Inspection Report 05000133/2020-001 and 07200027/2020-001

On November 3-4, 2020, the U.S. Nuclear Regulatory Commission (NRC) performed a routine on-site inspection of the decommissioning and the Independent Spent Fuel Storage Installations (ISFSI) activities at the Humboldt Bay Power Plant (HBPP) in Eureka, California.

The inspection included an evaluation of the current condition of the ISFSI, decommissioning activities, and reviews of several topical areas to evaluate compliance with the applicable NRC regulations and the provisions of the sites Part 50 and Part 72 specific license. The inspection included reviews of documentation relevant to decommissioning and ISFSI activities and operations that occurred at HBPP since the last decommissioning inspection performed in August 2019 (ADAMS Accession No. ML19262G962) and the last ISFSI inspection performed in April 2018 (ADAMS Accession No. ML18170A065). The documentation reviewed included quality assurance records, radiological surveys, corrective action reports, and records demonstrating compliance with Part 50 and Part 72 Technical Specifications, Post-Shutdown Decommissioning Activities Report, and the ISFSI Final Safety Analysis Report (FSAR)

requirements. The NRC inspectors did not identify any violations in either program area.

Organization, Management, and Cost Controls at Permanently Shutdown Reactors, Inspection Procedure 36801

• The licensee continued to manage site staffing, site training, independent reviews, corrective actions, and audit programs in accordance with quality assurance program requirements. (Section 1.2)

Decommissioning Performance and Status Review at Permanently Shutdown Reactors, Inspection Procedure 71801

• The licensee continued to maintain a critical path method as stipulated in the Post-Shutdown Decommissioning Activities Report. The critical path included development and completion of all remaining final status survey reports. The licensee also continued to maintain a fire protection program as required by technical specifications. (Section 2.2)

Occupational Radiation Exposure, Inspection Procedure 83750

• The inspectors reviewed the status of the licensees radiation safety program and confirmed that the licensee could suspend the program based on site conditions. The inspectors also noted that the licensee continued to maintain control of the licensed site pending NRC review and approval of the remainder of the final status survey reports. (Section 3.2)

Radioactive Waste Treatment and Effluent and Environmental Monitoring, Inspection Procedure 84750

• The licensee continued to implement effluent and environmental monitoring programs in accordance with technical specifications and Off-site Dose Calculation Manual requirements. The licensee downgraded the monitoring programs based on site conditions and the status of decommissioning. (Section 4.2)

Solid Radioactive Waste Management and Transportation of Radioactive Materials, Inspection Procedure 86750

• The licensee managed, packaged, and shipped radioactive waste in accordance with procedural and regulatory requirements. (Section 5.2)

Away from Reactor ISFSI Inspection Guidance, Inspection Procedure 60858

• The inspectors reviewed the quality assurance audits and surveillances performed by the licensee since the last ISFSI inspection. Issues identified in the quality assurance audits and surveillances were entered into the sites corrective action program for resolution. No findings were identified related to the licensees ISFSI quality assurance activities.

(Section 6.2.a)

• Radiation levels around the ISFSI facility were within the expected ranges. The ISFSI facility was maintained in good physical condition. Based on documents reviewed and interviews with personnel, areas with observable degradation were repaired, tracked, or remediated through the sites maintenance program. At the time of the inspection there were no observable signs of degradation. (Section 6.2.b)

• Environmental data reviewed from the 2018 and 2019 site radiological environmental operating reports determined that radiation levels off-site were nominal and in accordance with the design basis and Title 10 of the Code of Federal Regulations (CFR) 72.104.

(Section 6.2.c)

• Since the last NRC ISFSI inspection, Humboldt Bay submitted a license amendment request to the NRC and completed two revisions to its FSAR. No issues were identified in the review of the changes associated with the license or FSAR. (Section 6.2.d)

• Selected condition reports were reviewed for the period of April 2018 through October 2020.

A wide range of issues were identified and resolved by the licensee. The issues identified did not have a significant impact on safety and resolution of those issues were appropriate.

No adverse trends were identified during the review. (Section 6.2.e)

• The Humboldt Bay Emergency Response Plan was being maintained and a revision to the plan was reviewed by the inspectors. The inspectors determined the changes did not reduce the effectiveness of the plan and did not require NRC approval pursuant to 10 CFR 72.44. Drills, exercises, and training were performed in accordance with requirements in the plan. Off-site support agencies were offered an opportunity to participate in the licensees latest biennial exercise. (Section 6.2.f)

• Annual maintenance inspections of the ISFSI system, overpacks, and components were completed in accordance with FSAR requirements. Only minor superficial surface issues were identified. (Section 6.2.g)

Review of 10 CFR 72.48 Evaluations, Inspection Procedure 60857

• The inspectors reviewed a sample of 10 CFR 72.48 screenings and evaluations that had been performed within the inspection period. No findings were identified through the selected sample review. (Section 7.2)

REPORT DETAILS

Summary of Facility Status

At the time of the inspection, four structures related to the decommissioned Unit 3 facility remained on-site. These structures (security building, count room, office building, and waste management facility) will be repurposed for other uses. Since the previous inspection of the 10 CFR Part 50 license, conducted in August 2019, the licensee completed all field work associated with decommissioning. Activities in progress at the time of the inspection included development and issuance of the various final status survey reports. The licensee had submitted nine of 14 reports, and six reports have been approved by the NRC. In the near future, the licensee plans to continue working on the remaining final status survey reports with the goal of terminating the Part 50 license by mid-2021.

The Humboldt Bay Independent Spent Fuel Storage Installation (ISFSI) was loaded with six Holtec International Storage, Transport, and Repository Cask System (HI-STAR) overpacks each containing a Multi-Purpose Canister (MPC). For Humboldt Bay, the overpack and MPC are designated as the HI-STAR Version HB and MPC HB, due to the smaller fuel assemblies that were utilized by their reactor. The six HI-STAR HB overpacks are located in a below-grade vault. Five of the HI-STAR HB overpacks contain up to eighty Boiling Water Reactor fuel assemblies in the MPC HBs, while the sixth overpack contained Greater Than Class C (GTCC)

waste within the MPC HB. The GTCC waste was segments associated with the dismantlement of the reactor vessel and other debris that was previously stored in the spent fuel pool. The ISFSI is maintained under a site-specific NRC Part 72 license. The overpacks at the Humboldt Bay ISFSI were loaded using SNM-2514 License Amendment 1 and Final Safety Analysis Report (FSAR) Revision 1 but were all currently maintained under SNM-2514 License Amendment 4 Renewed and the FSAR Revision 10.

Organization, Management, and Cost Controls at Permanently Shutdown Reactors (Inspection Procedure (IP) 36801)

1.1 Inspection Scope

The inspectors reviewed the licensees programs to control, evaluate, and manage decommissioning activities. The review included the licensees programs for site staffing, training, independent assessments, corrective actions, audits, and change control.

1.2 Observations and Findings

The inspectors reviewed the licensees organizational structure. The staffing requirements for decommissioning are provided in Section 1.2 of the Humboldt Bay Quality Assurance Plan (HBQAP), Revision 39, dated January 2020. Since the previous inspection, conducted in August 2019, the licensee reduced the number of on-site staff involved with decommissioning. At the time of the inspection, the licensee was revising the staffing requirements as specified in the HBQAP to reflect a reduction in work activities and program requirements at the site.

The Senior Vice President, Generation and Chief Nuclear Officer, was responsible for site decommissioning. The quality assurance staff reported to the Senior Vice President. The Humboldt Bay Power Plant Director was responsible for the conduct of

decommissioning activities. The decommissioning staff included on-site and off-site personnel that supported both radiological and non-radiological activities. In summary, the licensee had sufficient staff for the work in progress.

The HBQAP, Section 2.3, provides the training requirements. Training included indoctrination training as well as training and qualification in tasks requiring special skills or knowledge. During the first quarter of 2020, the licensee suspended radiological training due to removal of the remainder of the radioactive material from the site and completion of decommissioning field work. The licensee is no longer required to implement the instruction to worker requirements specified in 10 CFR 19.12 since site workers are no longer likely to receive an occupational dose in excess of 100 millirem per year.

Section 1.2 of the HBQAP includes requirements for the Independent Management Review, a high-level management oversight program. This review is periodically performed to assess the effectiveness of the quality assurance program. The inspectors reviewed the summary of the last review, conducted in July 2020. No deficiencies were identified involving the Unit 3 decommissioning project, but several enhancements were presented including the recommendation involving closure of corrective action reports that have been open for extended periods of time. The inspectors concluded that the Independent Management Review process met HBQAP requirements. The next Independent Management Review was scheduled for July 2022, unless the Part 50 license is terminated by that date.

The corrective action program requirements are provided in Section 16 of the HBQAP.

This section states that conditions adverse to quality shall be identified, controlled, reviewed, and evaluated to determine remedial action and corrective action, and implement those actions as soon as practicable. The inspectors briefly reviewed the status of the licensees corrective action program. The licensee continued to maintain its corrective action program. With regards to the decommissioning program, the activities involving quality included development of the final status survey reports and the management of the data used in the development of the reports. The licensee continued to review and close open corrective actions as recommended by the July 2020 Independent Management Review.

The inspectors reviewed the status of the licensees quality assurance audit program.

Routine audits are required by Section 18 of the HBQAP. This section states that, at a minimum, the conformance of decommissioning activities to applicable regulatory requirements is audited at least once every 24 months or more frequently as performance dictates. The last audit of the decommissioning program was conducted in October 2019 by the former radiation protection manager. The auditor did not identify any findings or deficiencies and provided one recommendation regarding amount of detail being provided to the NRC in the final status survey reports. The next audit is scheduled to be completed in 2021, unless the license is terminated before the audit is due to be performed.

The licensee voluntarily conducted a self-assessment in October 2020. The auditor identified one deficiency related to a procedural conflict. A corrective action report was issued to resolve this deficiency. The auditor also identified three program enhancements.

Finally, the inspectors reviewed the status of the licensees control of changes, tests, and experiments as specified in 10 CFR 50.59. By letter dated January 27, 2020 (ADAMS Accession No. ML20027B231), the licensee notified the NRC pursuant to 10 CFR 50.59(d)(2) there were no 50.59 evaluations for changes made to the Unit 3 facility in 2018-2019. The inspectors confirmed, though conversations with licensee representatives, that no 50.59 evaluations were conducted in 2020. Thus, this program area was not reviewed during the inspection.

1.3 Conclusions

The licensee continued to manage site staffing, site training, independent reviews, corrective actions, and audit programs in accordance with quality assurance program requirements.

Decommissioning Performance and Status Review at Permanently Shutdown Reactors (IP 71801)

2.1 Inspection Scope

The inspectors evaluated whether the licensee was conducting decommissioning activities in accordance with procedural, license, and regulatory requirements.

2.2 Observations and Findings

Section 3.0 of the Post-Shutdown Decommissioning Activities Report dated July 2013 (ADAMS Accession No. ML13213A160) states that the licensee will develop a critical path method to reflect long-range planning and coordination for the project. The inspectors reviewed and discussed the current critical path report with licensee representatives.

At the time of the inspection, the critical path consisted primarily of development of final status survey reports and responding to NRC comments on previously submitted reports. At the time of the inspection, the licensee had submitted nine of 14 reports to the NRC, and the NRC had approved six of the reports. As noted earlier, the licensee plans to complete all reports, and respond to all NRC comments, by mid-2021 to allow for termination of the 10 CFR Part 50 license.

Section 5.5.1 of technical specifications, an appendix to the Part 50 license, states that written procedures shall be established, implemented, and maintained for the fire protection program. Details of the program are provided in Section 4.2 of the Defueled Safety Analysis Report, Revision 14. As noted in the Defueled Safety Analysis Report, the potential for a major fire was greatly diminished, and the fire suppression, detection, and alarm systems have been downgraded to standard industrial safety requirements.

The inspectors discussed the status of the fire protection program with licensee representatives. At the time of the inspection, the licensee continued to maintain a program with a dedicated fire marshal with fire watches as needed. Fire-fighting equipment included on-site fire extinguishers with off-site support as needed.

Contingency actions were taken as needed if system components were disabled. The licensee also continued to conduct pressure and flow tests of hydrants. In summary, the

licensee continued to implement a fire protection program as stipulated in technical specifications and the Defueled Safety Analysis Report.

2.3 Conclusions

The licensee continued to maintain a critical path method as stipulated in the Post-Shutdown Decommissioning Activities Report. The critical path included development and completion of all remaining final status survey reports. The licensee also continued to maintain a fire protection program as required by technical specifications.

Occupational Radiation Exposure (IP 83750)

3.1 Inspection Scope

The inspectors reviewed the licensees occupational radiation exposure program for compliance with regulatory requirements.

3.2 Observations and Findings

By letter dated March 25, 2020 (ADAMS Accession No. ML20086G381), the licensee notified the NRC that individual monitoring was not required for calendar year 2019.

The licensee conducted routine surveys of work areas and equipment in 2019 to demonstrate that individual monitoring was not required. Thus, the licensee did not file an annual report of occupational radiation exposure for 2019.

The inspectors discussed the status of the radiation protection program with licensee representatives. Based on site conditions and the status of decommissioning, the licensee suspended the radiation protection program for the 10 CFR Part 50 license in February 2020. In particular, the licensee suspended the radiation protection program procedures, routine area surveys, and training. As noted in the Defueled Safety Analysis Report, Section 5, there no longer exists a radioactive material inventory at the Unit 3 site. Further, Section 5.4.3 documents that the radiation protection program has essentially been suspended due to the status of the Unit 3 site.

License DPR-7, Condition 2.C.4, references a cross-contamination program. This program was designed to prevent recontamination of remediated areas from areas that were still being remediated. The licensees representatives stated that the cross-contamination program was suspended in February 2020, coincident with the suspension of the remainder of the radiation protection program.

The inspectors reviewed the status of the radiation protection program relative to site conditions and concluded that the program could be suspended since the site had been decommissioned and no radioactive material remained on-site. However, the inspectors also noted that the NRC has not reviewed and approved all final status survey reports which will demonstrate that the site has been effectively remediated. Until License DPR-7 is terminated, the licensee continued to maintain control of the property while it continued to document the results of its final status survey program.

3.3 Conclusions

The inspectors reviewed the status of the licensees radiation safety program and confirmed that the licensee could suspend the program based on site conditions. The inspectors also noted that the licensee continued to maintain control of the licensed site pending NRC review and approval of the remainder of the final status survey reports.

Radioactive Waste Treatment and Effluent and Environmental Monitoring (IP 84750)

4.1 Inspection Scope

The inspectors reviewed the radioactive waste treatment and effluent and environmental monitoring programs to determine if the licensee was effectively controlling, monitoring, and quantifying releases of radioactive material in liquid, gaseous, and particulate forms to the environment.

4.2 Observations and Findings

a.

Effluent and Environmental Monitoring

The technical specifications, an appendix to NRC License DPR-7, require the licensee to establish, implement, and maintain an Off-site Dose Calculation Manual (ODCM).

Section 4.1 of the ODCM requires the licensee to prepare an annual report on the status of the decommissioning radiological environmental monitoring program. The most recent report was submitted to the NRC by letter dated April 30, 2020 (ADAMS Accession No. ML20121A264). This report provides the results of effluent and environmental monitoring that was conducted in calendar year 2019. As required by Section 4.2 of the ODCM, the licensee also submitted the annual radioactive effluent release report for 2019 to the NRC by letter dated March 25, 2020 (ADAMS Accession No. ML20086G381). This letter included changes made to the ODCM during 2019.

The inspectors reviewed the status of the effluent and environmental monitoring programs and discussed the information presented in the two reports with licensee representatives. During 2019, the licensee monitored airborne radioactivity and direct radiation exposures at both on-site and off-site locations. There were no identified gaseous or liquid effluent releases in 2019. The licensee concluded that the results of monitoring demonstrated that site activities had no measurable radiological effect on the environment in 2019. The estimated dose to the maximum exposure individual was 0.1 millirem with a regulatory limit of 100 millirem per year.

During 2019-2020, the licensee reduced the size and scope of the effluent and environmental monitoring programs under the 10 CFR Part 50 license based on the status of decommissioning. As of February 2020, the licensee no longer possessed licensed radioactive material under its Part 50 license, and the licensee elected to suspend the effluent and environmental monitoring programs. The licensee will present the results of monitoring conducted in early 2020, prior to suspension of the programs, in the next annual report.

b.

Changes to the ODCM

The licensee is authorized to make changes to the ODCM per Appendix B to the HBQAP. The inspectors reviewed the changes made to the ODCM since the last inspection, conducted in August 2019 (ADAMS Accession No. ML19295D252).

The licensee revised the ODCM twice since the previous inspection.

The licensee issued Revision 31 to the ODCM in November 2019. The changes included deletion of the off-site air sampling station since there were no longer any airborne effluent releases from the site. This revision also changed sample analyses from the on-site laboratory to an off-site laboratory, since the licensee planned to transfer or dispose of all remaining radioactive check and calibration sources as part of decommissioning.

Revision 32 of the ODCM was issued in January 2020. This revision included substantial changes to the effluent and environmental monitoring program based on site conditions. Since site decommissioning had essentially been completed, and since there were no credible release pathways to be measured, the licensee suspended the remainder of the radiological environmental monitoring program in February 2020. The licensee also suspended the interlaboratory comparison program, since effluent and environmental samples were no longer being collected and analyzed.

In accordance with Section 4.1 of the ODCM, the licensee plans to continue to submit annual radiological environmental monitoring reports to the NRC until license termination; although, the information presented in future reports will be limited. In addition, the licensee plans to continue to submit annual radioactive effluent release reports to the NRC in accordance with Section 4.2 until license termination. The next annual radioactive effluent release report is expected to include information about radioactive waste shipments made in 2020 as well as discussion of Revision 32 to the ODCM.

4.3 Conclusions

The licensee continued to implement effluent and environmental monitoring programs in accordance with technical specifications and ODCM requirements. The licensee downgraded the monitoring programs based on site conditions and the status of decommissioning.

Solid Radioactive Waste Management and Transportation of Radioactive Materials (IP 86750)

5.1 Inspection Scope

The inspectors reviewed the radioactive waste management and transportation programs to determine if the licensee had properly processed, packaged, stored, and shipped radioactive material in accordance with procedural and regulatory requirements.

5.2 Observations and Findings

The inspectors reviewed the status of the licensees radioactive waste management and transportation program with licensee representatives. Since the last inspection, conducted in August 2019, the licensee accomplished the following transfers and shipments:

• Shipment of an intermodal container of radioactive exempt soil and debris to a disposal site in Idaho in September 2019

Shipment of a cargo container of radioactive exempt mixed waste and debris to the same Idaho disposal site in September 2019

Transfer of the liquid scintillation system and associated internal radioactive source to a generally licensed distributor in Illinois in November 2019

Transfer of a 55-gallon container of radioactive checks sources used during decommissioning to a waste broker in Tennessee in February 2020

The inspectors reviewed the documentation for the February 2020 shipment. The paperwork included a manifest and radiological surveys. The inspectors noted the documentation complied with U.S. Department of Transportation and 10 CFR Part 20, Appendix G requirements.

The licensee plans to make one final shipment consisting of radioactive exempt soil samples to the disposal site in Idaho. These samples were collected during decommissioning activities and contain background-level concentrations of cesium-137.

The shipment is expected to be completed by the end of the calendar year. The samples are currently being stored in a metal container within the owner-controlled area.

The licensee continues to store the soil samples in case the NRC requests additional information as part of its review of the final status survey reports.

To reduce the overall cost of waste material disposals, the licensee previously submitted three alternate disposal requests (exemptions) per 10 CFR 20.2002. The NRC approved the requests but placed limits on the quantities of waste material that could be disposed at the Idaho facility (see ADAMS Accession Nos. ML102870344, ML120620450, and ML12299A056). To demonstrate compliance with the alternate disposal limits, the licensee maintained records documenting the amount of material shipped under each of the three exemption requests. At the time of the inspection, the licensee had not exceeded any of the quantity limitations specified in the three exemption requests, and the licensee was unlikely to exceed any of the limitations since only one container of soil samples remained to be shipped.

5.3 Conclusions

The licensee managed, packaged, and shipped radioactive waste in accordance with procedural and regulatory requirements.

Away from Reactor ISFSI Inspection Guidance (IP 60858)

6.1 Inspection Scope

The inspectors performed a review of the licensees ISFSI activities to verify compliance with requirements of the site-specific License SNM-2514, License Amendment 4 Renewed, and FSAR Revision 10. The inspectors reviewed selected procedures, corrective action reports, and records to verify ISFSI operations were compliant with the license technical specifications, requirements in the FSAR, and NRC regulations.

6.2 Observations and Findings

a.

Quality Assurance Audits

Since the last ISFSI inspection, the Humboldt Bay quality assurance program had issued one 2019 audit report and one 2020 Independent Management Review Report that related to ISFSI activities. The licensees audit and surveillance program encompassed many topical areas and provided in-depth reviews of the licensees ISFSI programs, operations, training, and record keeping. The audits covered ISFSI documentation and activities related to ISFSI technical specifications; FSAR requirements; implementation of ISFSI programs; training and qualifications; design control; quality verification activities; and other ISFSI related areas.

All identified findings or enhancements were placed into the licensees corrective action program (CAP) as Condition Reports (CRs). Each CR required a formal response from the impacted program department. The inspectors reviewed the problem statements for each CRs that resulted from the two ISFSI audits. The CRs were evaluated to ensure that the problems being identified were properly categorized based on their safety significance and were properly resolved by the licensee. The inspectors determined corrective actions identified or taken for the issues were appropriate for the significance of the problems being identified. The inspectors did not identify any concerns related to the findings of the sites auditing and surveillance reports. The audits performed met the requirements of 10 CFR Part 72, Subpart G and the licensees quality assurance program requirements.

b.

Radiological Conditions and Tour of the ISFSI

A tour of the Humboldt Bay ISFSI was performed during the inspection. A recent radiological survey of the ISFSI was provided to the inspectors prior to their arrival at the facility. The ISFSI Program Manager accompanied the inspectors during the facility tour.

During the tour the inspectors determined that the concrete ISFSI vault and the vault lids were in good physical condition. The licensee utilized a maintenance program to inspect, repair, and assess the ISFSI structures and the HI-STAR HB overpacks (see Section 6.2.g). No flammable or combustible materials were observed anywhere inside or near the ISFSI vault. Radiation readings were taken near the ISFSI and remained at background levels. No areas within the ISFSI perimeter fence required postings in accordance with 10 CFR Part 20 requirements.

c.

Radiological Environmental Monitoring Reports

Humboldt Bay ISFSI Annual Radiological Environmental Monitoring Reports were reviewed for 2018 and 2019. The sites environmental monitoring program measured the direct radiation impacts of plant operations at 10 thermo-luminescent dosimeter (TLD) monitoring stations which surrounded the ISFSI. Four locations were in close proximity to the ISFSI vault and were located along the Security Area Fence. The other six locations were further away from the ISFSI but were within the Security Boundary Fence.

The ISFSI Security Boundary Fence locations are the ones used to demonstrate compliance with the 10 CFR 72.104 requirements for radiation dose. For the two-year period reviewed by inspectors, the dose at TLD locations along Security Boundary Fence were equivalent to background levels. The dose results demonstrated the maximum dose to an individual of the public was well below the 10 CFR 72.104(a)(2)

requirement of less than 25 mrem per year. No findings were identified related to the radiological review.

d.

Changes to the SNM-2514 License and FSAR

At the time of the last inspection conducted in April 2018, Humboldt Bay utilized SNM-2514 License Amendment 4 and FSAR Revision 6. Since then, Humboldt Bay received a 40-year license renewal for the ISFSI from the NRC on June 10, 2020.

The SNM-2514 ISFSI License Amendment 4 Renewed has an expiration date of midnight on November 17, 2065.

The FSAR was revised from Revision 6 to Revision 9 in one change. The revision was all editorial corrections/changes and updates to reflect facility changes due to decommissioning activities. The major changes associated with license Amendment 4 Renewed and FSAR Revision 10 was the inclusion of License Condition 19 and FSAR Section 9.4.3, titled License Renewal Aging Management. This program established the processes and procedures to manage the aging of ISFSI components into extended storage periods. Per the License Condition 19, the Aging Management Program is required to be implemented at least one year prior to the period of extended operation.

For Humboldt Bay, the SNM-2514 had set to expire on November 17, 2025 before the 40-year extension. At the time of the inspection, Humboldt Bay was in the process of developing the Aging Management Plan and its implementing procedures that would envelop the FSAR Section 9.4.3 requirements, which was reviewed and approved by the NRC during the license renewal process. The licensee expects to meet the License Condition 19 and begin the Aging Management Plans assessments, inspections, and maintenance prior to the November 17, 2024 deadline.

e.

Corrective Action Program

The inspectors performed a review of Humboldt Bays CAP associated with ISFSI operations. A list of ISFSI related CRs issued since the last routine NRC inspection in April 2018 was provided by the licensee during the current inspection. Several CRs were selected by the inspectors for further review.

The conditions discussed in the CRs reviewed by the inspectors covered a broad range of paperwork and maintenance issues that were identified during routine ISFSI storage

operations. Based on the types of problems identified, the licensee continued to demonstrate a reasonably low threshold for placing ISFSI and maintenance issues into the CAP. The actions taken for the resolution of the issues were appropriate to the low safety significance of the issues that were identified. No significant safety concerns or adverse trends were identified during the review of the CAP at Humboldt Bay.

f.

Emergency Planning

Revisions to the licensees Emergency Plan since the last NRC inspection in April 2018 were reviewed. The Humboldt Bay Emergency Plan, HBI-L4, Revision 9 had been issued in October 2018. The changes to the Emergency Plan were related to significant revisions due to decommissioning activities that had been completed on-site. Additional changes included updating maps, editorial corrections, removal of decommissioning personnel participants, and decommissioning related procedures from the plan. The inspectors determined the changes did not result in a decrease in the effectiveness of the plan and pursuant to 10 CR 72.44, the changes did not requirement NRC approval.

Required emergency drills/exercises were listed in Section 8.3 of the plan. Required annual drills included radiological/health physics drills, medical drills, and fire drills.

Biennial exercises were larger drills that tested the adequacy of the implementing procedures, emergency equipment, and communications networks and ensured the emergency response personnel were familiar with their duties. Off-site response organizations were invited to participate in the biennial exercises. The licensee had successfully conducted the required exercises and drills since the last ISFSI inspection.

A sample of drill packages and the most recent biennial exercise were selected for review. The inspectors determined that the selected drills and the exercise met the objectives of the site Emergency Response Plan. No concerns were identified with the licensees implementation of their Emergency Response Plan.

g.

Concrete Casks, ISFSI pad, and Transfer Station Annual Visual Inspection

Humboldt Bay FSAR Section 9.4.1.1.3 required procedures to be established for performing preventive and corrective maintenance on Humboldt Bay ISFSI systems, equipment, and components. The inspectors reviewed the results of the annual inspection Procedure HBI-450 ISFSI Inspection and Monitoring, Revision 9.

Procedure HBI-450 required inspections of the vault cells and overpacks using a borescope. Additional inspections were required of the ISFSI concrete, vault lid, and lid sealants. All steel, concrete surfaces, including the HI-STAR HB overpacks within the vault were visually inspected for defects and irregularities.

The defects/irregularities that were identified were placed in the sites CAP for resolution.

The inspectors verified that no significant issues were identified by the licensee during those inspections. All small defects/irregularities such as small holes and pitting were noted for repair or tracking to ensure the issues did not significantly increase in size.

The inspectors found that the licensees implementation of their annual maintenance program was performed with significant attention to detail. No issues were identified related to the licensees annual maintenance program.

6.3 Conclusions

The licensee conducted quality assurance audits and surveillances of the ISFSI program. The inspectors reviewed the quality assurance audits and surveillances performed by the licensee since the last ISFSI inspection. Issues identified in the quality assurance audits and surveillances were entered into the sites CAP for resolution. No findings were identified related to the licensees ISFSI quality assurance activities.

Radiation levels around the ISFSI facility were within the expected ranges. The ISFSI facility was maintained in good physical condition. Based on documents reviewed and interviews with personnel, areas with observable degradation were repaired or remediated through the sites maintenance program. At the time of the inspection there were no observable signs of degradation.

Environmental data reviewed from the 2018 and 2019 site radiological environmental operating reports determined that radiation levels off-site were nominal and in accordance with the design basis and Title 10 of the Code of Federal Regulations (CFR) 72.104.

Since the last NRC ISFSI inspection, Humboldt Bay submitted a license amendment request to the NRC and completed two revisions to its FSAR. No issues were identified in the review of the changes associated with the license or FSAR.

Selected CRs were reviewed for the period of April 2018 through October 2020. A wide range of issues were identified and resolved by the licensee. The issues identified did not have a significant impact on safety and resolution of those issues were appropriate.

No adverse trends were identified during the review.

The Humboldt Bay Emergency Response Plan was being maintained and a revision to the plan was reviewed by the inspectors. The inspectors determined the changes did not reduce the effectiveness of the plan and did not require NRC approval pursuant to 10 CFR 72.44. Drills, exercises, and training were performed in accordance with requirements in the plan. Off-site support agencies were offered an opportunity to participate in the licensees latest biennial exercise.

Annual maintenance of the ISFSI system, overpacks, and components inspections were completed in accordance with FSAR requirements. Only minor superficial surface issues were identified.

7.

Review of 10 CFR 72.48 Evaluations (IP 60857)

7.1 Inspection Scope

The licensees 10 CFR 72.48 screenings and evaluations performed since the NRCs last ISFSI inspection were reviewed to determine compliance with regulatory requirements.

7.2 Observations and Findings

The licensee performed several procedure revisions, two FSAR revision, and some equipment or process changes under the 10 CFR 72.48 process since the last inspection. The inspectors reviewed the 10 CFR 72.48 screenings for those changes made within the ISFSI program. None of the screenings led to a 10 CFR 72.48 full evaluation. All screenings were determined to be adequately performed.

7.3 Conclusions

The inspectors reviewed a sample of the licensees required safety screenings and evaluations that had been performed within the inspection period. No findings were identified during the selected sample review.

8.

Exit Meeting Summary

On November 4, 2020, the inspectors presented the final inspection results of the decommissioning inspection to Mr. Eric Nelson, Director Nuclear Decommissioning and other members of the licensees staff.

On November 4, 2020, the inspectors presented the final inspection results of the ISFSI inspection to Mrs. Paula Gerfen, Diablo Canyon Power Plant Site Vice President and other members of the licensees staff.

Attachment

SUPPLEMENTAL INSPECTION INFORMATION PARTIAL LIST OF PERSONS CONTACTED

Licensee Personnel B. Barley, Site Closure Manager K. Braico, Senior Engineer W. Dunham, ISFSI Regulatory Assurance Manager B. Lopez, Licensing L. Mayfield, ISFSI Manager K. Rowberry, Site Closure Specialist/Training Coordinator

INSPECTION PROCEDURES USED

IP 36801 Organization, Management, and Cost Controls at Permanently Shutdown Reactors IP 71801 Decommissioning Performance and Status Review at Permanently Shutdown Reactors IP 83750 Occupational Radiation Exposure IP 84750 Radioactive Waste Treatment and Effluent and Environmental Monitoring IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive

Materials IP 60858 Away from Reactor ISFSI Inspection Guidance IP 60857 Review of 10 CFR 72.48 Evaluations

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened None

Closed None

Discussed None

LIST OF ACRONYMS USED

ADAMS Agencywide Documents Access and Management System CAP Corrective Action Program CFR Code of Federal Regulations CR Condition Report DNMS Division of Nuclear Material Safety FSAR Final Safety Analysis Report GTCC Greater Than Class C HBPP Humboldt Bay Power Plant HBQAP Humboldt Bay Quality Assurance Program HI-STAR HB Holtec International Storage, Transport, and Repository Cask System HB IP Inspection Procedure ISFSI Independent Spent Fuel Storage Installation MPC multi-purpose canister NCV non-cited violation NRC U.S. Nuclear Regulatory Commission ODCM Off-site Dose Calculation Manual PGE Pacific Gas and Electric TLD thermo-luminescent dosimeter