ML13274A050
| ML13274A050 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 08/20/2013 |
| From: | NRC/FSME |
| To: | |
| Hickman J | |
| References | |
| NRC-144 | |
| Download: ML13274A050 (45) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Humboldt Bay Decommissioning Process License Termination Plan Docket Number: (n/a)
Location: Eureka, California Date: Tuesday, August 20, 2013 Work Order No.: NRC-144 Pages 1-45 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 1 UNITED STATES OF AMERICA 2 + + + + +
3 NUCLEAR REGULATORY COMMISSION 4 + + + + +
5 HUMBOLDT BAY DECOMMISSIONING PROCESS 6 LICENSE TERMINATION PLAN 7 + + + + +
8 PUBLIC MEETING 9 + + + + +
10 TUESDAY, 11 AUGUST 20, 2013 12 + + + + +
13 EUREKA, CALIFORNIA 14 15 PRESENT:
16 BILL BARLEY, PG&E 17 ROB EVANS, NRC 18 JOHN HICKMAN, NRC 19 TANYA OXENBERG, NRC 20 KAREN PINKSTON, NRC 21 LOREN SHARP, PG&E 22 BLAIR SPITZBERG, NRC 23 BRUCE WATSON, NRC 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 P-R-O-C-E-E-D-I-N-G-S 2 MR. WATSON: Well, good evening. And we 3 welcome you tonight. We have this room from six to nine.
4 We'd like to close down about 8:45 so we can get our 5 equipment out of here and be in compliance with the 6 contract for the building.
7 My name is Bruce Watson. I'm chief of the 8 reactor decommissioning branch in NRC in headquarters.
9 My branch is responsible for the licensing activities at 10 Humboldt Bay, and so we are basically the licensing 11 authority and regulator for the site.
12 In the back, there are some critique sheets.
13 There's also some index cards for people who want to ask 14 questions that would like to write it down rather than 15 use a microphone. We are having this meeting recorded, 16 so the actual meeting minutes will be available.
17 We are here to discuss the Humboldt Bay 18 License Termination Plan. The plan was submitted to the 19 NRC for approval. We have conducted what we call an 20 acceptance review. That typically takes a few months 21 for us to look at the broad look at the actual document.
22 Acceptance does not mean approval. We are required to 23 hold a public meeting to obtain comments from the public 24 when the -- after the LTP is submitted and accepted for 25 the detail review. And that's where we are right now.
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3 1 We will be starting our detailed review here now, right?
2 Okay. With me tonight are John Hickman.
3 He's the project manager for the Humboldt Bay site. We 4 have Blair Spitzberg, Dr. Blair Spitzberg, from our 5 regional office. He's the chief of the people who 6 inspect the -- conducting inspections at Humboldt Bay.
7 Also we have -- from the NRC, we have Dr. Tanya Oxenberg, 8 she is conducting the health physics review of the 9 licensed termination plan, and Dr. Karen Pinkston, and 10 she does the dose assessment and environmental 11 evaluation. And we have, also, Dr. Rob Evans. He's the 12 inspector for the site. He's from Region IV out of our 13 Arlington, Texas office.
14 From PG&E, we have Loren Sharp. He's the 15 PG&E director and nuclear plant manager. And we have 16 Bill Barley who's the Humboldt state closure manager for 17 PG&E.
18 Our agenda is pretty simple. First, I'm 19 going to make a couple of opening remarks. John Hickman 20 will discuss what's required to be in a License 21 Termination Plan. Loren and Bill will talk about the 22 actual license termination plan as submitted. And Blair 23 will talk about the inspection process for 24 decommissioning. Then we'll go to some Q&As, questions 25 and answers, hopefully; get your comments and solicit NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 1 whatever feedback you can on the LTP at this point.
2 I would like for you to limit your questions 3 to maybe one or two so we have -- can give other people 4 the opportunity to talk since we do have a limited amount 5 of time.
6 Let me go to my slide here I've put together.
7 Our regulations for decommissioning have 8 been in place since 1997. We did have some other cleanup 9 regulations before that, but the current regulations 10 went into place in 1997. And as a result of that, we have 11 some significant experience in decommissioning, in 12 particular, reactor decommissioning.
13 We have terminated the licenses of eleven 14 reactors in the U.S., seven of those were under the 15 current regulations. And we've also terminated over 50 16 material licensees, complex material licensees, and 13 17 research reactors.
18 So the breadth of the experience is fairly 19 good. The inspection process is well established. If 20 you go to our website, you can find our inspection manual 21 chapter which Blair and his folks follow from the region 22 on conducting inspections, and we'll talk about that in 23 more detail.
24 As you already know, our oversight 25 continues once the plant stops operation and goes into NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 1 decommissioning. It does not stop until we terminate 2 the license. And so we want you to assure you that we're 3 here to make sure that the decommissioning is conducted 4 safely and securely throughout the entire process until 5 all the material -- radioactive material is removed and 6 the license is terminated.
7 So with that, I was going to invite John 8 Hickman up and he's going to talk about the license 9 termination process.
10 MR. HICKMAN: This is an overview of the 11 decommissioning process for a reactor facility.
12 First step is where the licensee decides 13 that they're going to terminate operations in their 14 facility. In the case of Humboldt Bay, that occurred in 15 June of 1983.
16 Second step in the process for us is when 17 we actually amend the license to no longer allow 18 operations in the facility. The new regulations that 19 Bruce mentioned take care of that automatically. But in 20 the case of Humboldt Bay, they shut down before those 21 regulations were in place. So the license was amended 22 in July of '88 to no longer permit operation at the 23 facility.
24 After that, the licensee, in this case, 25 Humboldt, submitted a decommissioning plan describing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 1 basically how they're going to begin their 2 decommissioning process. You have to include the 3 planned decommission activities. In the case of 4 Humboldt, they went into safe store for about 5 approximately 30 years. They have to provide us a 6 schedule to the activities they want to do.
7 In their initial submittal, obviously, with 8 30 years of safe store, it didn't go into a lot of detail.
9 But they subsequently provided information when they 10 went began active decommissioning and the other actions 11 they've taken. They also have to provide a cite for the 12 cost estimate.
13 Additionally, they have to submit, 14 annually, financial reports on their expenditures and 15 status of the decommissioning trust fund. So we 16 maintain continual observation of their trust fund and 17 progress of decommissioning. And that's what the union 18 share when they send it in.
19 The next step in the process is the License 20 Termination Plan. When -- at least two years prior to 21 completion of the decommissioning, when they want to have 22 the license terminated, they need to submit a License 23 Termination Plan. We'll go into some more detail on 24 that. And that's the focus of that meeting as they have 25 now submitted that plan.
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7 1 After the License Termination Plan is 2 approved and they complete the decommissioning, they 3 will then begin a final set of surveys where they're going 4 to survey the site to determine if they have 5 decommissioned it if compliance with the plan and to the 6 levels we require. And after that is done, we would then 7 be terminating the license.
8 Our regulations are specific in certain 9 aspects of decommissioning, such that they cannot do any 10 activities that would not allow the release of the site 11 for unrestricted use, so they wouldn't be able to 12 terminate the site and release it completely, not result 13 in any environmental impacts that were not previously 14 considered. Environmental evaluations were performed 15 for licensing of the site and operation of the facility, 16 and they cannot do any actions through decommissioning 17 that would cause any impacts beyond what had previously 18 been evaluated.
19 They also cannot take any actions through 20 decommissioning that result in there not being 21 sufficient funds to complete the decommissioning. And 22 that's part of why we monitor the funding annually.
23 The focus during decommissioning is on 24 these primary areas, the removal of the facility from 25 service, the reduction of radioactive materials to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 1 level that allows us to terminate the license, and 2 detailed radiological surveys of the site they conduct 3 and confirmatory surveys that we'll be conducting.
4 This is an outline of what the LTP needs to 5 include. Pacific Gas & Electric will go into more detail 6 on the content of the License Termination Plan, but I just 7 wanted to give a sort of overview of what the LTP is.
8 It's essentially a document that is an agreement with us 9 as to how they're going to cleanup the site to meet our 10 release criteria, how they're going to do the surveys to 11 prove that they've cleaned up the site sufficiently.
12 Our release criteria is dose based. The 13 regulations state that following decommissioning the 14 residual plant-generated radiological materials cannot 15 contribute more than 25 millirems per year dose to an 16 individual. To put that in context, the average person 17 in the United States is exposed to approximately 350 18 millirems per year from background radiation.
19 The 25 millirem per year is based on a dose 20 modeling that has to be done. They'll go into it -- the 21 licensee will go into it in a little more detail. But 22 the dose modeling process assumes that there's going to 23 be an individual, in this case, it's called a resident 24 farmer scenario, who, following the license termination, 25 would choose to establish his residence an farm on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 1 site. They have to analyze all the pathways by which 2 that individual could be exposed to the residual 3 radioactive material, determine what level of radiation 4 can be left that would limit the dose of that person to 5 25 millirems per year, and then they would do the surveys 6 to confirm that the level that is actually left is less 7 than that analyzed level.
8 So it's fairly complicated, but it 9 basically models the dose so they can take a radiation 10 measurement of the site to the surveys and know that 11 there's little enough material left that the dose would 12 not exceed that 25 millirem per year.
13 This is basically the review process for the 14 License Termination Plan. As Bruce mentioned, we've 15 already completed our acceptance review. That's 16 basically just the look at the License Termination Plan 17 to insure they included all the required information and 18 it appears to have enough substance for a technical 19 review.
20 Second step is our technical review. We 21 have done that now. Typically, it takes about a year.
22 Frequently, it also requires some questions. I don't 23 believe we've ever had a License Termination Plan where 24 we didn't have some questions on it. So we would have 25 a request for additional information to be provided to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 1 get whatever additional information we needed.
2 We are required to have a public meeting.
3 That's why we're here today. We also have an opportunity 4 for comment from the public, and it's not just at this 5 meeting tonight. When we get to the end of my slides, 6 my e-mail address will be listed there. If anybody wants 7 more information on the License Termination Plan, if 8 anybody wants to provide comments on the License 9 Termination Plan, you can contact me at any time during 10 our review process. It's not -- it doesn't just have to 11 be tonight.
12 Assuming the License Termination Plan is 13 reviewed and determined to be acceptable, it is approved 14 by a license amendment. The reason for that is it then 15 becomes part of the facility's license. They have to 16 comply with the plan with exceptions that may be noted.
17 But it is not a -- it's a somewhat inflexible document.
18 They have certain aspects they have to comply with as they 19 completed the decommissioning. And NRC, during the 20 process, will also perform inspections of what's going 21 on and confer with the facility.
22 This is the latter part of the survey of the 23 process through the License Termination Plan. As they 24 get near the end of their termination process, they will 25 be submitting final status surveys. This is where they NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 1 would go out, conduct radiological surveys of any kind 2 of structures if there were any structures left, 3 although, Humboldt is not planning on leaving any 4 standing; they will conduct surveys of the soil in areas 5 that are going to be released in the license, all with 6 the intent of showing that they've met the cleanup 7 criteria that was established in the plan.
8 The NRC would review and approve those final 9 status survey reports, confirming that they are meet our 10 expectations for detail and the data is the kind of 11 numbers we would need. We also have contractors from Oak 12 Ridge who would come in and do confirmatory surveys 13 because we want to have independent eyes come in and do 14 the same surveys to verify that their surveys were 15 actually performed adequately. And assuming both their 16 surveys and our surveys show that the site has been 17 decontaminated to the appropriate levels, the license 18 would then be terminated.
19 This is the contact information. Anybody, 20 if you want to jot down the e-mail address, if you want 21 to contact either myself or Blair at the regional office, 22 any questions either on the License Termination Plan or 23 any aspects of the decommissioning process, either now 24 or later, be happy to hear from you.
25 And the point at the bottom bullet there, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 1 we have an electronic meeting room available on the 2 Internet. You can access the License Termination Plan 3 there, if you want to. It is available in our ADAMS 4 system. If you have any trouble finding that, you can 5 ask me. And I think I even have about eight copies of 6 it on CD, so if somebody wants a copy tonight, I'll be 7 happy to give it to you.
8 MR. WATSON: Thank you, John.
9 Loren, you're next.
10 MR. SHARP: So we're going to give you a 11 little status of where we're starting the License 12 Termination Plan from, where we've achieved our actual 13 decommissioning to date, and we'll go ahead and provide 14 a little bit of the status of what we've accomplished so 15 far. And then Bill will give you a little bit more update 16 on exactly what we've done with the License Termination 17 Plan.
18 So the line in yellow outlines all the 19 property that is under the Part 50 license at Humboldt 20 Bay. So we will have to clean up and remediate all the 21 property inside of that line in order to get acceptable 22 relief and termination of the license from the NRC.
23 This slide shows a little bit of the 24 overview of the site. Again, this is where the Unit 3 25 structure is. This is where Units 1 and 2 used to be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 1 before we demolished those. And we'll finish 2 the -- based on those that were done with the lay down 3 the area.
4 This shows the infrastructure that we put 5 in place in the 2009 and '10 time frame. We put in 6 trailers for housing the office personnel. We put in a 7 road for access as well as the scales and truck portal.
8 And we also put in a radiological access building in 2010.
9 This photo shows exactly what our status is 10 right now at this point. This shows how it was 11 constructed, ground level being at this level plus 12.
12 This is roughly minus 66 below grade. This area shows 13 the actual reactor vessel, the reactor dry well, the 14 bio-shield wall and the outer caisson.
15 What's important to note about the reactor 16 vessel is everything inside of the reactor vessel has 17 been removed. We have removed all the reactor 18 internals; we have drained the reactor vessel; and we are 19 in the process right now of removing the control drive 20 mechanisms underneath the vessel. Once we've completed 21 with that, we'll go into the reactor vessel segmentation.
22 This shows some of the items that we have, 23 indeed, removed from the reactor vessel and as well as 24 the spent fuel pool. We took out the spent fuel pool 25 racks after we sent the dry cask storage up the hill with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 1 the fuel in them in 2008.
2 In the upper right, the control rod blades 3 were put into a shield cask and we then moved them over 4 into a pool. We actually shipped out -- there are two 5 shipments of control rod blades. The first one went out 6 yesterday, and the second shipment will go out next week 7 to Texas.
8 This is the main steam line we removed from 9 the reactor head space. And then this is the lower core 10 shroud that we cut up and removed. It's been shipped to 11 Texas in some of our B and C waste shipments.
12 The yellow diagram shows the location of 13 what we're going to install as a slurry wall. And we'll 14 show a few more details of that in a minute. We're going 15 to put a slurry wall down to minus 170 foot elevation so 16 we can protect the ocean from the site as we go after 17 removal of the structures down below grade.
18 This shows a little bit of how that slurry 19 wall will work. We essentially would end up putting down 20 a slurry wall down to the clay layer, which is minus 170.
21 And this portion, although not depicted accurately, this 22 is like minus 80. And we would remove the water down to 23 like minus 80.
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15 1 underground. And after we've got the slurry walls 2 installed by this type of machine, and then we would 3 remove the infrastructure. So that's kind of how the 4 slurry wall goes in to allow us to take this structure 5 out. It's commonly used in construction of plants near 6 water bodies to make sure they can construct them.
7 Now I'll turn it over to Bill.
8 MR. BARLEY: All right. Go into a little 9 bit about what is specifically in our License Termination 10 Plan. As John Hickman talked about, the process that we 11 have is -- and exactly where we are right now in the 12 process is up here. As you can see, we submitted our plan 13 on May 3rd. It has been through the NRC acceptance 14 review. And we have the public meeting tonight. And we 15 anticipate that the review will be completed sometime out 16 in next year.
17 I'll go through the different chapters that 18 we have. We have eight chapters in the LTP. The first 19 chapter is pretty much a summary of the history of the 20 site that defines the years that it operated, some of the 21 problems that we had over the years, just a running 22 scenario of that reactor operation that occurred back in 23 those days.
24 And also, it addresses a little bit of an 25 overview of what the rest of the chapters contain. So NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 1 as a "pick it up and read it" document, this is one you 2 might want to look at and just get a feel for what's in 3 the overall document.
4 The second chapter is where we have 5 assembled all of the characterization data that was done 6 so that we could plan our decommissioning. By 7 assembling all the different radiological information 8 that we had, we could then go off and plan the details 9 that we'll see in the rest of this document. So this 10 chapter presents that summary in a very easy-to-read 11 format. For people who are familiar, they'll be able to 12 use that in their review as they look at the rest of our 13 document to assess whether or not our plans are adequate 14 for going forward with the rest of our decommissioning.
15 Chapter 3, then, looks at, where are we in 16 the decommissioning process, because we've been at this 17 for a few years already. What we've done, at a very high 18 level at this point because we're still working out some 19 of the minor details going forward. But at a high level, 20 we've laid out those activities that we still have to do, 21 like Loren talked about for installation of the slurry 22 wall, the removal of the caisson and large structures 23 like that that we have on-site, in addition to the final 24 status survey that was just done and other 25 end-of-the-document reports writing we have to do.
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17 1 Chapter 4, then, presents all the different 2 processes that we may be using in order to remediate the 3 site and get down to that release level that John talked 4 about. So we have to get down to the 25 millirem to that 5 individual in any one year. And this lays out all those 6 various processes that we have at our disposal that we 7 will be using throughout the decommissioning process.
8 Chapter 5, then, lays out our plans for 9 doing this final status survey. How will we do all of 10 these various surveys to accumulate the data that the NRC 11 is going to need to assess that, yes, we do meet that final 12 clearance criteria at the end when we want to terminate 13 the license. It lays out exactly how we're going to 14 survey the units, how we're going to assess the data that 15 we get back, how our data quality requirements form that 16 data. So a lot of detail in here that lays out 17 specifically how that program will work so they can 18 review that in detail and ensure themselves that, yes, 19 we've laid out a good plan to get forward to accumulate 20 the data that they're going to need to terminate the 21 license.
22 Chapter 6 is where we get into his 23 discussion about how did we come up with that clearance 24 criteria. So of all the chapters, this is the most 25 technical, challenging one to get through. We use NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 1 various computer programs that are approved. We develop 2 site-specific criteria that we input to that program and, 3 through that, develop a level at which we must get to to 4 demonstrate compliance with that end state. And this 5 will probably be one that Karen will spend a lot of time 6 with looking at and getting back to us.
7 Chapter 7, then, goes into the funding 8 requirements for the site. So here we have laid out 9 exactly what we see as the required funding to complete 10 the rest of the decommissioning and what our plans are 11 for that, to assess that funding to get us to the end 12 state.
13 And again, the NRC will look at that and say, 14 does this look reasonable? So every step along the way, 15 they'll be reviewing this submittal that we give to them 16 to ensure that we haven't missed something, have them ask 17 us questions, and we'll be giving them additional 18 information in this area as more is developed.
19 And then, finally, Chapter 8. We talked 20 about -- John talked about the fact that we have to look 21 at, we're not going to do any environmental degradation 22 above the plans that we already had in place. So what 23 we've had to do is look at all the various things that 24 we're going to be doing the rest of the project and assess 25 them against the general criteria for decommissioning NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 1 plants that's out there and to assure ourselves and the 2 NRC that it's within all of the expected environmental 3 problems that we would expect to see in another 4 decommissioning plant somewhere.
5 And I think, with that, I turn it over to 6 Blair next.
7 MR. SPITZBERG: Good evening.
8 My name is Blair Spitzberg. And I'm from 9 the Region IV office of the NRC. Most people think that 10 NRC being in Washington D.C. and our headquarters is near 11 Washington D.C. in Rockville, but we have four regional 12 offices.
13 And ours happens to be geographically the 14 largest, is the western half of the United States 15 basically. And we do all the inspections of licensees 16 that NRC licenses within all of those states. And we go 17 out as far as Hawaii and Alaska and American Samoa and 18 Guam and a couple of other small places out west. But 19 we do cover a large area.
20 And our office is in Arlington, Texas, which 21 most of you probably know is between Dallas and Fort 22 Worth, and we're very close to the airport. So we have 23 the ability to get on planes and come out to sites on short 24 notice. Fortunately, we don't have to do that often.
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20 1 there was an event or an accident or something that we 2 needed to come out and look into fairly rapidly, we are 3 able to do that.
4 The way we regulate decommissioning 5 basically is fairly straightforward. I think most of 6 you would be able to come up with the same criteria that 7 we use to regulate. We establish and ensure adherence 8 to the requirements which are contained fundamentally in 9 the regulations. Title 10 of our regulations is where 10 most of our requirements are, but we also rely on 11 regulations from EPA and OSHA that we also have a role 12 in enforcing, Department of Transportation.
13 And then we also have a whole collection of 14 safety standards that we issue, ourselves. And some of 15 them are safety standards that we rely on other aspects 16 of the safety community to establish the standards that 17 we, then, commit our licensees to through the license.
18 And then the license is active until license termination.
19 And it contains license conditions and technical 20 specifications. And so those establish the criteria 21 that we inspect against.
22 What we're here tonight for is the License 23 Termination Plan which was just submitted recently. And 24 this is the second aspect of how we regulate safety, is 25 performing licensing reviews and safety evaluations. And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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21 1 that's what John is talking about, that this is going to 2 be a process by which they'll be performing the technical 3 review of the License Termination Plan. Once this 4 License Termination Plan is in place and approved, then 5 we will inspect against that License Termination Plan and 6 all the commitments that the licensee has made in that 7 plan.
8 And finally, the way that we ensure safety 9 is by performing inspections and taking enforcement when 10 necessary. And that's what the regional offices do, for 11 the most part. We send inspectors out to the sites on 12 a regular basis, and we do rather invasive inspections.
13 And most of our inspections are a announced, but some of 14 them can be unannounced. We can carry a multitude of 15 inspectors who have different expertise in different 16 areas. I have a number of inspectors who are specialists 17 in the decommissioning arena, but if we need somebody 18 that is a specialist in another technical area, whether 19 it's health physics or environmental monitoring or in the 20 case of -- believe it or not, in some cases in 21 decommissioning, there's construction that takes place, 22 for example, the slurry wall that they're planning to put 23 in place here. We'll probably have to have some 24 inspectors with a different background and expertise 25 come out and look at the installation of the slurry wall.
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22 1 So just let me cover the types of 2 inspections that we do and have been doing for years since 3 Humboldt Bay shut down permanently. We do regular 4 decommissioning inspections out there. That's my staff 5 that does that. And we quite often will have folks from 6 our headquarters office accompany us on those 7 inspections.
8 And we generally try and schedule these 9 inspections during periods of activity that we consider 10 to have a higher risk associated with it. So if they're 11 removing a large component or if they're cutting a piece 12 of a facility that may have become highly activated 13 during the years of operation, or if they're moving some 14 spent fuel or some radioactive waste, something that may 15 be of a slightly higher risk than the normal routine 16 decommissioning activities, that's what we try to target 17 our inspections around and -- so that we can come out and 18 look at that activity and also look at the training and 19 the records and everything associated with that and doing 20 independent measurements. And we'll go through all 21 these inspection procedures, but I wanted to convey the 22 fact that we do try to -- because I have a limited staff, 23 to try and target our inspections for those higher-risk 24 activities.
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23 1 here is this acronym called ISFSI, independent spent fuel 2 storage installation. For those of you who don't know, 3 the majority of the fuel that was used at Humboldt Bay 4 is still on-site, but it has been removed from the spent 5 fuel pool and put in what we call dry casks. And they're 6 specifically licensed for the dry casks at this site.
7 And it will remain in the dry cask until the federal 8 government establishes a repository for this fuel to be 9 sent to.
10 And so the good news that this spent fuel 11 is all in dry casks; it's out of the pool so that they 12 can now dismantle their spent fuel pool. And I have 13 inspectors on my staff that do ISFSI routine inspections 14 and will continue to do this beyond when the Part 50, the 15 reactor license is terminated in few years.
16 And we also have physical security 17 inspections that are performed by a different group 18 within the region and they come out an perform specific 19 inspections on the security systems at the site.
20 So what is it we try and do during the 21 inspection? We try and verify whether there's -- when 22 the licensee is conducting their activities safely and 23 in compliance with the license. We try and verify 24 whether there's adequate licensee controls on their 25 processes, whether they have procedures in place for all NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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24 1 of the processes that they're undertaking, whether they 2 have reviewed and approved the procedures and the 3 procedure changes that are required to effectively and 4 safely implement those activities. We ensure safety 5 problems and violations are promptly identified and 6 corrected and that effective corrective action is taken 7 to prevent recurrence. And then we also, for periods of 8 time, we examine trends in licensee safety and 9 performance.
10 This list, I'm not going to go through the 11 whole list, but this is a list of our core inspection 12 procedures that we utilize during the decommissioning 13 process. And if you look at this, it covers just about 14 everything. We get down into -- for example, they have 15 to have an organization that meets what they committed 16 to in their License Termination Plan or in their license.
17 So if they don't have the specific personnel staff in 18 positions that are important to safety, for example, like 19 whether they have operators or radiation safety folks, 20 health physics folks, environmental monitoring 21 specialists, they have to have those positions filled.
22 And so we look that those positions are filled by 23 qualified individuals.
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25 1 their facilities and their procedures. We look at their 2 self-assessments and their quantity assurance audits and 3 their corrective action program.
4 I mentioned that we do separate independent 5 spent fuel storage installation inspections, so we do 6 look at the safety of the fuel as it's being stored. We 7 look at the occupational radiation exposure, the final 8 status surveys. We do surveys throughout the 9 decommissioning process.
10 My inspectors are all health physicists, 11 and they're well-trained and they have a bevy of 12 instruments that we bring out to the site to do 13 independent surveys. And then we also have a contractors 14 laboratory in Oak Ridge that we also have come out at 15 various times during the decommissioning process to do 16 verification surveys.
17 At the end of this process when the 18 licensees tells us that they're ready, that they've met 19 the release criteria for the site, we'll do extensive 20 surveys at that time using our contractor laboratory to 21 verify that. But we do it in process as well.
22 We also look at radwaste treatment, 23 effluent monitoring and environmental monitoring. We 24 look at transportation when we move materials. We were 25 just looking at packaging of a waste package today, or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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26 1 yesterday when we arrived. We look at maintenance and 2 surveillance and, as I mentioned, physical security. And 3 also look at their contingency procedures and processes.
4 Okay. So what we do with these inspections 5 once we complete them? We're a public agency. We owe 6 the public the information that -- on how we regulate.
7 And we think we do a pretty good job of trying to 8 communicate that, this meeting being one example. But 9 we communicate with the public every day on our website, 10 nrc.gov.
11 And for the most part, with few exceptions, 12 all of our inspection reports are publicly available. The 13 only ones that are normally not publicly available are 14 the ones that speak to physical security issues that 15 we -- that our physical security inspectors look at.
16 Their reports are -- portions of them are public. But 17 any sensitive information having to do with the physical 18 security systems in place at the site would not be made 19 public for obvious reasons.
20 But our decommissioning inspection reports 21 are all made publicly available, and they're all 22 available on our website. And we hope that you would 23 take advantage and look at them from time to time to keep 24 an eye on how we're looking after activities at the site.
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27 1 with the program office, Bruce's office. He's got a group 2 of license reviewers and experts in Washington in the 3 decommissioning arena, and I have the inspectors, so we 4 talk all the time back and forth between our office in 5 Arlington and their office in Washington to help us 6 refine and determine how best to perform our inspections, 7 what activities to look at. And we coordinate quite 8 extensively with them.
9 We normally will send out an inspection 10 schedule with them at least a year in advance. We don't 11 always adhere to the dates on the schedule, but we do try 12 and conduct the number of inspections that we plan to 13 conduct. And as I mentioned, they quite often will come 14 out with us. And we'll adjust the schedule during the 15 year as needed and based upon licensee activities and 16 balancing our inspection schedule out here with our 17 inspections that are needed at some of the other plants 18 where there's maybe a higher-risk activity occurring at 19 the same time.
20 In order to plan and execute the inspection, 21 as I mentioned, they could be announced; they could be 22 unannounced. We find that usually there's merit in 23 announcing our inspections if we're looking at a specific 24 area. We want to make sure that the people are going to 25 be there that we need to talk with.
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28 1 But we're also able to do inspections, and 2 we do do inspections that are unannounced. And 3 sometimes we do an unannounced inspection for the benefit 4 of following up on, for example, on allegations, 5 something like that, where we need to talk to somebody 6 or somebody may have contacted us and we need to go out 7 and look after a concern that they have.
8 Breach inspection is an inspection plan 9 that's developed. And that comes to me for approval. And 10 we'll talk about what that particular inspection will 11 cover and come to an agreement on that. And we'll sign 12 off on the inspection plan before it's executed.
13 And then after the inspection, the 14 inspector will hold an exit meeting with the 15 licensee -- normally at the end of the week; it can be 16 done telephonically when they get back to the regional 17 office, but normally it's at the end of week -- where we 18 brief the licensees on our preliminary findings. And 19 this is where we would identify any potential violations 20 that are identified, whether the licensees is in 21 compliance, whether there's any follow-up issues.
22 Then when the inspector comes back to the 23 office, he will debrief before the management in the 24 Region IV office, and we'll quite often have the 25 headquarters folks come, and say what the findings are.
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29 1 And we'll make an agency determination of what the 2 findings are. And then based on that, the inspector will 3 go back and write his or her report and will issue that 4 report.
5 Down at the bottom of the slide, most of our 6 inspection reports are issued within 30 days. If we have 7 a team inspection, we're given a 45-day window to 8 complete the inspection report because it involves more 9 inspector input, and they're usually more lengthy 10 reports.
11 I put up there the location where you can 12 find our enforcement policy. If there are violations, 13 we have a very well-defined enforcement policy on how we 14 treat the violations. As you might expect, the 15 violations will be treated based upon their 16 significance, and so we have different categories.
17 Depending upon what category the violation is identified 18 in, whether it's in health physics or transportation or 19 management organization, quality assurance, whatever 20 the category it's in, we have a supplement to our 21 enforcement policy that defines what the significance of 22 the violation would be.
23 And then based upon that, we'll determine 24 whether or not we issue a notice of violation to the 25 licensee or whether we can document the violation in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 1 report. For those cases where the violations are more 2 significant, we have other options available. We can 3 have enforcement conferences with the licensees; we can 4 issue monetary civil penalties; we can modify the 5 license; we can issue orders. There's a whole 6 assortment of enforcement tools available to us.
7 The good news is that we very seldom have 8 to implement that because, for the most part, the 9 licensees that we regulate are good, in compliant 10 licensees. And we don't often find significant 11 violations, but we do on occasion. And when we do, we 12 have the tools available to us to take the necessary 13 enforcement to prevent recurrence.
14 And then finally, at the end of the 15 inspection process, we also keep a list of things we need 16 to follow-up on in future inspections so that we will not 17 let issues drop that we need to come back and look at again 18 and again and again.
19 Okay. So I've already talked about what 20 happens after the inspection, so I think I've covered 21 what's on this slide.
22 I just want to mention where you can find 23 our inspection reports. If you go to the website here 24 in this slide at nrc.gov, the ADAMS webpage, you can look 25 up inspection reports by docket number. And I don't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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31 1 recall the docket number off the top of my head. But if 2 any of you want to ask that at the end -- oh, it's up there.
3 05000133 is the docket number. And if you look under 4 that, you'll be able to find all of our safety inspection 5 reports.
6 Okay. So how many inspections do we do?
7 Normally, right now we're doing about one a quarter. But 8 as I mentioned, as activity at the site dictate, you know, 9 we'll send inspectors out for the critical activities.
10 But we have been, for the last couple years, been doing 11 somewhere between four and six inspections a year, about 12 one a quarter.
13 Inspections typically last a full week that 14 we're onsite. And they can consist of one or more 15 inspectors. Quite often, they'll consist of at least 16 two inspectors. But this week, for example, we were 17 conducting an inspection. And Rob Evans out here in the 18 audience is one of my senior inspectors, and he's 19 conducting inspections this week.
20 Talked about enforcement. We have a 21 categorization of severity levels for the violations 22 that we identify. Anything that's Severity Level 3 or 23 above is considered escalated enforcement. There's 24 been one case of escalated enforcement in recent years 25 out here. It did involve a security matter that I can't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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32 1 talk about tonight. But it with a Severity Level 3, so 2 it was just in the category that we consider for escalated 3 enforcement, but it wasn't the highest category. And 4 that's been taken care of and resolved. Otherwise, we 5 have a good recent enforcement history with this licensee 6 going back to the start of the decommissioning work.
7 And then I put my coordinates up there. If 8 anybody would like to call me, I'd welcome you to call 9 me or to send me an e-mail. If you have any questions, 10 I'll be glad to get back with you. And also my division 11 director, Tony Vegel, his address is up there. And our 12 Region IV main switchboard number is up there as well.
13 So please avail yourself of those numbers if you'd like 14 to get in touch with the inspection office in Region IV, 15 we welcome that.
16 So with that, turn it back to Bruce.
17 MR. WATSON: It's question and answer time, 18 or question and comment time. Does anybody have any 19 comments? Or would you like to take a five-, ten-minute 20 break and then we'll start?
21 No?
22 Like I said, we do have complete sheets in 23 the back. We would like you to complete those. You can 24 just put those in the post to us, or you can leave them 25 with us. There's also some index cards back there that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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33 1 if you want to write a question down and pass them up, 2 we'll be happy to respond to those also.
3 Yes, sir?
4 MR. ENNIS: I'd like to make some comments.
5 MR. WATSON: Can you state your name for us, 6 please?
7 MR. ENNIS: Yes. My name is Michael Ennis.
8 I moved to Humboldt County in 1964, a couple years after 9 the power plant went into operation.
10 And I spent 31 years as an engineer, the last 11 at 21 at Humboldt State University in the Department of 12 Environmental Engineering. And I taught environmental 13 science, environmental issues, energy issues. And 14 consequently, I was very well-versed with not only the 15 nuclear power plant but also with fossil fuel units and 16 pretty much all the energy stuff we're doing here in the 17 county.
18 In 1987 when the final, I guess, 19 environmental impact statement was issued, I taught a 20 class at Humboldt State, I had 36 students, on 21 decommissioning nuclear power plants. And it was a real 22 eye-opener for me. I never worked harder in all my life 23 and learned so much in a short period of time. But I 24 learned a lot and met a lot of people. And I think my 25 qualifications as someone to speak about nuclear power NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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34 1 are kind of there.
2 I retired from teaching in 2003. And since 3 1998, I've been on the Community Advisory Board and 4 working very closely with PG&E, and obviously aware of 5 why we're here today.
6 I just want to give you a little bit of 7 background about Humboldt County. We're a pretty unique 8 place. Aside from our notorious reputation, this is a 9 relatively small county that is made up of some very 10 unique, talented, wonderful, wonderful people. And we 11 take our environment very, very seriously. Everything 12 from, in the '60s, when Redwood National Park was formed, 13 everything from the infamous headwater forests that was, 14 again, nationwide news. If you step outside one your 15 way, you'll see a shell of one of the two pulp mills that 16 were basically shut down because they couldn't meet the 17 regulatory standards. We're active in toxic sprays on 18 our forests. I mean, the list goes on and on and on.
19 The variety of people here care about their 20 environment. And our most treasured and our most 21 precious piece of the environment is Humboldt Bay. And 22 we find that, not only is it an ecological treasure, we 23 have a national wildlife refuge; we have a variety of 24 state and local preserves, Arcata Marsh, if you have a 25 chance to go up there. We see the Bay as an important NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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35 1 resource for commerce. And we hope to, at some point, 2 expand shipping through here, but we also have fisheries, 3 we have oyster fisheries.
4 And probably the most important thing that 5 we have is the recreation on Humboldt Bay. All kinds of 6 trails, all kinds of access, and you can go out anytime 7 of the week and you will find people basically using that.
8 So this brings us to the nuclear power 9 plant. For basically 50 years, the residents of 10 Humboldt County have lived with the -- whatever words we 11 want to use, the fear, the concern, the issue of safety 12 in terms of the power plant, earthquakes, tsunamis. If 13 you were here in June of 1992 we had three separate 7.0 14 earthquakes in a 24-hour period. Pretty wild.
15 The plant operated 14 years. Science 16 Magazine, in 1972, called it the dirtiest plant in the 17 nation. We remember that. The spent fuel has been in 18 a pool for a long, long time. And luckily enough it is 19 now in a secure -- I feel very confident. I worked with 20 PG&E in terms of getting this ISFSI up. And I feel that 21 it is the best possible solution in terms of earthquakes 22 an tsunamis. And I hope that it will last for a long time 23 because they may have to last a very long time. And yet 24 we still live with this fear and this concern that there 25 is spent fuel that's here and may be here for a long period NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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36 1 of time.
2 The final thing, cleaning up the site. And 3 again, with the advisory committee, we spent a lot of time 4 talking about this, how clean is it, you know? How all 5 those acronyms, all those things that, you know, you deal 6 with on an everyday basis, it all boils down to us, the 7 residents of Humboldt County, looking out on this bay and 8 saying, "This is a treasure." And that site has to be 9 cleaned up to the utmost.
10 And I think that the plan that PG&E has come 11 up with, basically, meets that. And so therefore, I want 12 to ask you, I guess, want you to assure the public that 13 you, as the NRC, the final ruling on the decision, you 14 have the ultimate say that you basically give us the words 15 that we've lived with for so many years, that nuclear 16 power is clean, safe, and cheap. At least you can live 17 up to part of that mantra.
18 Thank you.
19 MR. WATSON: I guess I'll just add a couple 20 of comments, and thank you for your comments.
21 Our limitation is, our criteria are this 25 22 millirem per year. And it also includes the concept of 23 ALARA. And like I said, we have terminated the licenses 24 at eleven reactors so far. Seven of those have been 25 under our current regulations. And with each one of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 1 those, those terminations were conducted and completed 2 with rigorous inspections, rigorous blind sampling, 3 split sampling, confirmatory surveys.
4 And the results of those terminations were 5 that, in reality, the actual criteria were well-met and 6 were only a few fractions -- a small fraction, I should 7 say, of the 25 millirems when the licensee completed the 8 termination of the license. And like I said before, we 9 will not terminate any license until the licensee 10 demonstrates to us that they have complied with the 11 license termination criteria. And we're there to verify 12 it all the way to the end.
13 Any other questions? Comments?
14 State your name please.
15 MR. BOHN: I'm Rex Bohn. I've lived here 16 since the '50s. I haven't lived here in quite as much 17 fear, but I've lived within two or three miles as the crow 18 flies, since I was a pup.
19 I'm the first district supervisor of 20 Humboldt County and vice-chair. And we submitted a 21 letter to the Nuclear Regulatory Commission, and on 22 behalf of the Humboldt County Board of Supervisors, we 23 support the Humboldt Bay Power Plant License Termination 24 Plan that was recently submitted for your consideration 25 by Pacific Gas & Electric.
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38 1 The plan submitted is a well-thought-out 2 approach to addressing the challenges of decommissioning 3 the former nuclear power generation station in a manner 4 that is safe for the local community and the environment.
5 It goes on to say that we have full faith 6 in the plan that has been brought forth. I think the 7 citizens -- I'm also on the Citizens Advisory Committee.
8 I'm newer on the Citizens Advisory Committee, but I think 9 the plan that PG&E has brought forth, the transparency, 10 and especially what they've done to the community to 11 relieve the fears, and maybe that's why I haven't had 12 these fears. And it may be just lack of education, or 13 it may be I've got bigger things to worry about, and I 14 don't know what they are right now.
15 But I'm saying, as we move forward, I would 16 love to give full trust and full power to the powers that 17 be, you guys, to let this proceed. Loren and his team, 18 I don't know how many community meetings we had. And I 19 think -- I was up there today, and they're doing water 20 sampling on the channels at the request of the citizens 21 and working with the citizens on that. So I compliment 22 PG&E.
23 The Board of Supervisors ratify in this 24 letter that you got on a 5-0 vote. They have appeared 25 in front of the Board many times to explain what they are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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39 1 doing. And at the drop of a hat, they will do it at any 2 other time. So again, the Board of Supervisors 3 appreciates Humboldt County. And I appreciate the job 4 they're doing for our citizens.
5 Thank you.
6 MR. WATSON: Thank you for the comments.
7 Appreciate that.
8 I think one of processes that the NRC 9 promotes is having the community involved in the 10 decommissioning process. We entrusted the utility to 11 operate the plant for the number of years that they chose 12 to operate it, and we expect them to also safely 13 decommission the plant. And part of that is getting the 14 community involved so they understand what is going on 15 and what activities are going to be conducted at the site 16 so that they can convey to everybody in the community how 17 those things are done and how it's important that they 18 are done safely.
19 Do we have any other comments, questions?
20 Come on up. Can you state your name, 21 please?
22 MS. HALL: Jessica Hall, I'm a Humboldt 23 Baykeeper. So I understand that you can't talk about the 24 specifics of the violation that you described, or one of 25 you described, but I'm curious to know what the reasons NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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40 1 were that you couldn't share the details of that.
2 And you talk about the recent history of the 3 decommissioning process being -- going on very safely.
4 If you have any reflections on what happened prior to 5 that, I would also love to hear that.
6 MR. HICKMAN: Let me speak first to the 7 security violations. One of the aspects of nuclear 8 safety that we're responsible for ensuring is the 9 security of nuclear materials. And that includes 10 nuclear materials that are possessed or generated by 11 nuclear power plants, of which Humboldt Bay is one and 12 they have nuclear materials. They have to have a 13 physical security plan that we approve to safeguard the 14 nuclear materials in their possession. And we perform 15 inspections of the physical security plans.
16 Some of the requirements of the physical 17 security plans are that when a licensee violates any 18 aspect of that physical security plan, depending upon 19 what the violation is, they have to notify us. I don't 20 remember exactly the time frame. This was a couple years 21 ago. They notified us that they had violated an aspect 22 of a physical security plan.
23 And that's about as much as I can say about 24 what the violation was. But I just wanted to explain the 25 context of how we regulate the physical security NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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41 1 activities at the site and what they pertain to.
2 The second question was, I think, the 3 inspection record going back over time. You're racking 4 my brain now. We did have -- there was another case of 5 escalated enforcement back around ten years ago. And 6 that was something that we held public meetings out here 7 on, and we interacted with the public when they 8 were -- when Humboldt Bay was doing a full assessment of 9 all the fuel and the forms of the fuel that they had in 10 their spent fuel pool.
11 And they had a discrepancy in their records 12 that indicated that a small portion of a their fuel -- of 13 a fuel rod was unaccounted for. So as a result of that, 14 the licensee went into an exhaustive search where they 15 went through every little piece of everything that was 16 in there spent fuel pool; they examined all over the 17 plant; they looked at all their historical records of 18 what may or may not have been shipped off as waste and 19 so forth.
20 And they came out with a set of scenarios 21 that explained what the potential pathways for this were.
22 And we agreed with that, in effect; but as a result of 23 that, even though they went through this exhaustive 24 investigation, we concluded that they had lost 25 accountability for this small amount of spent fuel rod.
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42 1 And as a result of that, there was a civil penalty that 2 was about --
3 I don't remember, Dave, do you remember?
4 It was about ten years ago. Yeah. Since that time, you 5 know, as far as the decommissioning activities at the 6 site, we've not identified any significant violations 7 that had risen to the point of us taking escalated 8 measures.
9 Did that answer your question?
10 MS. HALL: Yes. Thank you.
11 MR. WATSON: Additional questions?
12 Please feel free.
13 PARTICIPANT: Maybe I can get just, like, 14 a show of hands, I'd like to see how many people are here 15 from the public, and not the NRC and PG&E.
16 So public people? We're overwhelmed.
17 Thank you.
18 MR. WATSON: Well, hearing no other 19 questions, I just thought I'd make a couple closing 20 remarks. And I'll go back up to the podium for that.
21 Again, let me thank you for attending and 22 providing your comments. In closing, I want to 23 emphasize three points.
24 The NRC will be here to ensure that Humboldt 25 Bay completes the decommissioning safely and securely.
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43 1 We will only terminate the license when they demonstrate 2 to us that they have met all the site criteria and the 3 site regulations for ensuring that the site meets our 4 criteria for terminating the license. We will continue 5 our inspections of Humboldt Bay all the way to the end, 6 and actually, inspections will continue with the ISFSI 7 afterwards.
8 We have begun our initial review of the 9 license termination plan. We expect that this detailed 10 technical review will take approximately a year. So 11 again, we would ask you if you have any comments, you can 12 go to our website, you can e-mail John or Blair or myself 13 with any comments you have on the LTP. And we look 14 forward to hearing any additional comments you may have 15 that if you do take the time to look at the LTP, it is 16 fairly extensive as it's intended to be. It's fairly 17 technical. And we look forward to any comments that you 18 may have. So I appreciate you coming tonight. And 19 thank you very much.
20 (Whereupon, the above-entitled matter 21 concluded at 7:05 p.m.)
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44 1
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