IR 07200027/2025001
| ML25070A293 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay (SNM-2514) |
| Issue date: | 03/13/2025 |
| From: | Jeffrey Josey NRC/RGN-IV/DRSS/DIOR |
| To: | Gerfen P Pacific Gas & Electric Co |
| References | |
| IR 2025001 | |
| Download: ML25070A293 (1) | |
Text
March 13, 2025
SUBJECT:
HUMBOLDT BAY INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) - NRC INSPECTION REPORT 07200027/2025-001
Dear Paula A. Gerfen:
This letter refers to the U.S. Nuclear Regulatory Commissions (NRCs) announced routine inspection conducted on February 4-6, 2025, of the Independent Spent Fuel Storage Installation (ISFSI) activities and the license renewal inspection. The NRC inspectors discussed the results of this inspection with Maureen Zawalick, Vice President of Business and Technical Services, and other members of your staff during the final exit meeting conducted on February 18, 2025.
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, license renewal conditions, and the regulations in Title 10 of the Code of Federal Regulations (CFR) Part 72.
The NRC inspectors did not identify any violations.
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, Jeffrey E. Josey, Chief Decom., ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Docket No.72-027 License No. SNM-2514 Enclosure:
Inspection Report 07200027/2025-001 Signed by Josey, Jeffrey on 03/13/25
ML25070A293 X SUNSI Review By: LEB ADAMS:
X Yes No Sensitive X Non-Sensitive Non-Publicly Available X Publicly Available Keyword NRC-002 OFFICE SSSFI:DRSS:DIORB SFSI:DRSS:DIORB TA:DRSS C:DRSS:DIOR NAME LBrookhart JFreeman BTharakan JJosey SIGNATURE
/RA/
/RA/
/RA/
/RA/
DATE 03/12/25 03/11/25 03/11/25 03/13/25
Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket No.:
07200027 License No.:
SNM-2514 Report No.:
07200027/2025-001 Enterprise Identifier:
I-2025-001-0094 Licensee:
Pacific Gas & Electric Company Humboldt Bay Power Plant Location:
Eureka, California 95503 Inspection Dates:
On-site: February 4-6, 2025 Exit Meeting Date:
February 18, 2025 Inspectors:
L. Brookhart, Senior ISFSI Inspector Decom., ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security, Region IV J. Freeman, Reactor/ISFSI Inspector Decom., ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security, Region IV B. Tharakan, CHP Technical Assistant Division of Radiological Safety and Security, Region IV Approved By:
Jeffrey E. Josey, Chief Decom., ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security, Region IV
EXECUTIVE SUMMARY NRC Inspection Report 07200027/2025-001 On February 4-6, 2025, the U.S. Nuclear Regulatory Commission (NRC) performed a routine on-site inspection of 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, ISFSI license renewal, and reviews of several topical areas to evaluate compliance with the applicable NRC regulations and the provisions of the sites part 72 specific license. The inspection included reviews of documentation relevant to ISFSI activities and operations that occurred at HBPP since the last ISFSI inspection performed in November 2020 (ADAMS Accession No. ML20336A192). The documentation reviewed included quality assurance records, radiological surveys, corrective action reports, and records demonstrating compliance with Part 72, technical specifications, and the ISFSI final safety analysis report (FSAR) requirements. The NRC inspectors did not identify any violations.
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 1.2.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 or aging management program. At the time of the inspection there were no observable signs of degradation. (Section 1.2.b)
Environmental data reviewed from the 2020-2023 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 1.2.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 1.2.d)
Selected condition reports were reviewed for the period of November 2020 through January 2025. 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 1.2.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 participated in the licensees latest biennial exercise. (Section 1.2.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 1.2.g)
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 1.2.h)
ISFSI License Renewal Inspection, Inspection Procedure 60859
Inspectors determined that Pacific Gas and Electric (PG&E) had adequately established their aging management program in accordance with all license renewal conditions. The licensee had performed all required inspections prior to the period of extended operations.
Based on the results of the licensees baseline inspection, the inspectors concluded that no significant issues were identified that required corrective actions or mitigating actions.
(Section 2.2)
REPORT DETAILS Summary of Facility Status 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 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 5 and the FSAR revision 12.
1.
Away from Reactor ISFSI Inspection Guidance (IP 60858)
1.1 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 5, and FSAR revision 12. 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.
1.2 Observations and Findings a.
Quality Assurance Audits Since the last ISFSI inspection, the Humboldt Bay quality assurance program had issued three audit reports and two independent management review reports 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 five 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 and aging management program to inspect, repair, and assess the ISFSI structures and the HI-STAR HB overpacks (see Section 1.2.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 2020-2023. 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 near 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 five-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 November 2020, Humboldt Bay utilized SNM-2514 license amendment 4 (renewed) and FSAR revision 10. Since then, Humboldt Bay has updated to license amendment 5. Changes included removing references to the now decommissioned facilities, submitting a revised quality assurance program under part 72, technical specifications changes related to loading of canisters, and various editorial in nature changes.
The FSAR was revised from revision 10 to revision 12 in two changes. Revision 10 to revision 11 involved updating various figures and discussing the cost of decommissioning and methods of funding. The revision 11 to revision 12 change involved removing the term SAFESTOR, the previous status of the site prior to decommissioning, and added the description of greater than class C waste as well as DOEs potential future role if a repository is identified. Additionally, changes were made in the FSAR to incorporate the recent changes approved in license amendment 5. The inspectors identified no concerns with the changes made by the licensee.
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 November 2020 was provided by the licensee during the current inspection. Multiple 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 November 2020 were reviewed. The Humboldt Bay emergency plan, HBI-L4, revision 12 had been issued in March 2024. 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 participated 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 required procedures to be established for performing preventive and corrective maintenance on Humboldt Bay ISFSI systems, equipment, and components. This section was recently modified to become the sites aging management program to meet license renewal conditions. The inspectors reviewed the results of the annual inspection procedure HBI-450 ISFSI Inspection and Monitoring, revision 13.
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.
h.
10 CFR 72.48 Safety Evaluations and Screenings The licensees 10 CFR 72.48 screenings and evaluations performed since the NRCs last ISFSI inspection were reviewed to determine compliance with regulatory requirements.
The licensee performed several procedure revisions, two FSAR revisions, and some process changes through the 10 CFR 72.48 program since the last inspection. The inspectors reviewed the 10 CFR 72.48 screenings and evaluations for those changes made within the ISFSI program. All screenings and evaluations were determined to be adequately performed.
1.3 Conclusions 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.
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 or aging management program. At the time of the inspection there were no observable signs of degradation.
Environmental data reviewed from the 2020-2023 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 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 condition reports were reviewed for the period of November 2020 through January 2025. 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 participated in the licensees latest biennial exercise.
Annual maintenance inspections of the ISFSI system, overpacks, and components were completed in accordance with FSAR requirements. Only minor superficial surface issues were identified.
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.
2.
ISFSI License Renewal Inspection (IP 60859)
2.1 Inspection Scope Inspectors assessed the licensees programs to implement aging management for structures systems or components, important to safety, to be adequately maintained consistent with the 10 CFR part 72 requirements, NRCs safety evaluation report, and site-specific license renewal requirements. Inspectors verified the license conditions, regulatory commitments, aging management programs, time limited aging analyses, and license renewal activities were implemented and/or completed, to verify that age-related degradation is identified and adequately managed or corrected, as applicable.
2.2 Observations and Findings The Humboldt Bay ISFSI site-specific license SNM-2514 was renewed on June 10, 2020, with an expiration date of November 17, 2065. license condition #19 required that PG&E create, update, and revise procedures for implementing the aging management programs that were approved as part of the license renewal application process at least one year prior to the period of extended operation (November 17, 2024). As part of that submittal, the FSAR section 9.4.3.3.1 required the baseline inspections per the aging management programs be performed and established prior to the period of extended operations (November 17, 2025).
The inspectors performed a comprehensive review of the licensees renewal application, NRC staff evaluation, licensee aging management programs, licensee implementing procedures, and the sites baseline inspection results. Inspectors confirmed the licensee adequately incorporated all aging management activities and commitments that were approved through the license renewal process into site programs and procedures.
Humbold Bays aging management program was divided into three large programs that encompassed all systems, structures, and components (SSCs) important to safety that had been evaluated by the licensee and approved by the NRC to require inspection and/or maintenance to ensure the SSCs would continue to perform their safety function and safely store spent fuel throughout the period of extended operation. For each of the aging management programs and their prospective procedures, the inspectors verified the licensee incorporated all applicable SSCs, correctly directed the parameters that required monitoring or inspection, contained the correct frequencies of inspection, and correct number of samples. The procedures directed the proper acceptance criteria
using the correct equipment and/or processes in accordance with the applicable code requirements. Inspectors verified the implementing procedures directed issues that did not meet acceptance criteria be placed into the corrective action program for evaluation and directed results of the inspections be placed in an industry operating experience database.
The licensee had performed all required baseline inspections prior to the period of extended operations, completing some of the aging management programs in 2022 and others in 2024. Inspectors determined that the programs and implementing procedures required the correct level of training and qualifications for individuals performing the activities and those evaluating the inspection results. The procedures directed activities in accordance with applicable industry code requirements using calibrated equipment and remote visual video equipment that met American Society of Mechanical Engineers (ASME) requirements. Qualification documentation was reviewed to verify the licensees nondestructive examiners met the code requirements of ASME, American Concrete Institute (ACI), or coating specialists with qualifications as outlined in NRCs safety evaluation report.
Inspectors reviewed the results of the completed inspections through a document review and videos that had been recorded of the inspection activities. Additionally, inspectors performed a walkdown of the ISFSI vault to observe the outside surfaces of the vault structure and visible sections of the vault lids. The licensee had established controls to begin trending the results of the inspections to ensure adequate monitoring and timely corrective or mitigative actions. Based on the results of the licensees baseline inspection, the inspectors concluded that no significant issues were identified that required corrective actions or mitigating actions and the licensee had met all license requirements associated with aging management implementation. No findings were identified.
2.3 Conclusions Inspectors determined that PG&E had adequately established their aging management program in accordance with all license renewal conditions. The licensee had performed all required inspections prior to the period of extended operations. Based on the results of the licensees baseline inspection, the inspectors concluded that no significant issues were identified that required corrective actions or mitigating actions.
3.
Exit Meeting Summary On February 18, 2025, the inspectors presented the final inspection results of the ISFSI inspection to Maureen Zawalick, Vice President of Business and Technical Services and other members of the licensees staff.
Attachment SUPPLEMENTAL INSPECTION INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel W. Dunham, ISFSI Business Operation Specialist L. Mayfield, ISFSI Manager G. Reed, Regulatory Services D. Madsen, Regulatory Services K. Duke, Dry Fuel Management Program INSPECTION PROCEDURES USED IP 60858 Away from Reactor ISFSI Inspection Guidance IP 60859 ISFSI License Renewal Inspection LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed None Discussed None
LIST OF ACRONYMS USED ACI American Concrete Institution ADAMS Agencywide Documents Access and Management System ASME American Society of Mechanical Engineers CAP Corrective Action Program CFR Code of Federal Regulations CR Condition Report DOE Department of Energy FSAR Final Safety Analysis Report GTCC Greater Than Class C HBPP Humboldt Bay Power Plant 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 NRC U.S. Nuclear Regulatory Commission PG&E Pacific Gas and Electric SSC systems, structures, and components TLD thermo-luminescent dosimeter