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
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UNITED STATES OF AMERICA 1
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2 NUCLEAR REGULATORY COMMISSION 3
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4 HUMBOLDT BAY DECOMMISSIONING PROCESS 5
LICENSE TERMINATION PLAN 6
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7 PUBLIC MEETING 8
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9
- TUESDAY, 10 AUGUST 20, 2013 11
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12 EUREKA, CALIFORNIA 13 14 PRESENT:
15 BILL BARLEY, PG&E 16 ROB EVANS, NRC 17 JOHN HICKMAN, NRC 18 TANYA OXENBERG, NRC 19 KAREN PINKSTON, NRC 20 LOREN SHARP, PG&E 21 BLAIR SPITZBERG, NRC 22 BRUCE WATSON, NRC 23 24 25
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P-R-O-C-E-E-D-I-N-G-S 1
MR. WATSON: Well, good evening. And we 2
welcome you tonight. We have this room from six to nine.
3 We'd like to close down about 8:45 so we can get our 4
equipment out of here and be in compliance with the 5
contract for the building.
6 My name is Bruce Watson. I'm chief of the 7
reactor decommissioning branch in NRC in headquarters.
8 My branch is responsible for the licensing activities at 9
Humboldt Bay, and so we are basically the licensing 10 authority and regulator for the site.
11 In the back, there are some critique sheets.
12 There's also some index cards for people who want to ask 13 questions that would like to write it down rather than 14 use a microphone. We are having this meeting recorded, 15 so the actual meeting minutes will be available.
16 We are here to discuss the Humboldt Bay 17 License Termination Plan. The plan was submitted to the 18 NRC for approval. We have conducted what we call an 19 acceptance review. That typically takes a few months 20 for us to look at the broad look at the actual document.
21 Acceptance does not mean approval. We are required to 22 hold a public meeting to obtain comments from the public 23 when the -- after the LTP is submitted and accepted for 24 the detail review. And that's where we are right now.
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We will be starting our detailed review here now, right?
1 Okay. With me tonight are John Hickman.
2 He's the project manager for the Humboldt Bay site. We 3
have Blair Spitzberg, Dr. Blair Spitzberg, from our 4
regional office. He's the chief of the people who 5
inspect the -- conducting inspections at Humboldt Bay.
6 Also we have -- from the NRC, we have Dr. Tanya Oxenberg, 7
she is conducting the health physics review of the 8
licensed termination plan, and Dr. Karen Pinkston, and 9
she does the dose assessment and environmental 10 evaluation. And we have, also, Dr. Rob Evans. He's the 11 inspector for the site. He's from Region IV out of our 12 Arlington, Texas office.
13 From PG&E, we have Loren Sharp. He's the 14 PG&E director and nuclear plant manager. And we have 15 Bill Barley who's the Humboldt state closure manager for 16 PG&E.
17 Our agenda is pretty simple. First, I'm 18 going to make a couple of opening remarks. John Hickman 19 will discuss what's required to be in a License 20 Termination Plan. Loren and Bill will talk about the 21 actual license termination plan as submitted. And Blair 22 will talk about the inspection process for 23 decommissioning. Then we'll go to some Q&As, questions 24 and answers, hopefully; get your comments and solicit 25
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whatever feedback you can on the LTP at this point.
1 I would like for you to limit your questions 2
to maybe one or two so we have -- can give other people 3
the opportunity to talk since we do have a limited amount 4
of time.
5 Let me go to my slide here I've put together.
6 Our regulations for decommissioning have 7
been in place since 1997. We did have some other cleanup 8
regulations before that, but the current regulations 9
went into place in 1997. And as a result of that, we have 10 some significant experience in decommissioning, in 11 particular, reactor decommissioning.
12 We have terminated the licenses of eleven 13 reactors in the U.S., seven of those were under the 14 current regulations. And we've also terminated over 50 15 material licensees, complex material licensees, and 13 16 research reactors.
17 So the breadth of the experience is fairly 18 good. The inspection process is well established. If 19 you go to our website, you can find our inspection manual 20 chapter which Blair and his folks follow from the region 21 on conducting inspections, and we'll talk about that in 22 more detail.
23 As you already know, our oversight 24 continues once the plant stops operation and goes into 25
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decommissioning. It does not stop until we terminate 1
the license. And so we want you to assure you that we're 2
here to make sure that the decommissioning is conducted 3
safely and securely throughout the entire process until 4
all the material -- radioactive material is removed and 5
the license is terminated.
6 So with that, I was going to invite John 7
Hickman up and he's going to talk about the license 8
termination process.
9 MR. HICKMAN: This is an overview of the 10 decommissioning process for a reactor facility.
11 First step is where the licensee decides 12 that they're going to terminate operations in their 13 facility. In the case of Humboldt Bay, that occurred in 14 June of 1983.
15 Second step in the process for us is when 16 we actually amend the license to no longer allow 17 operations in the facility. The new regulations that 18 Bruce mentioned take care of that automatically. But in 19 the case of Humboldt Bay, they shut down before those 20 regulations were in place. So the license was amended 21 in July of '88 to no longer permit operation at the 22 facility.
23 After that, the licensee, in this case, 24 Humboldt, submitted a decommissioning plan describing 25
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basically how they're going to begin their 1
decommissioning process. You have to include the 2
planned decommission activities. In the case of 3
Humboldt, they went into safe store for about 4
approximately 30 years. They have to provide us a 5
schedule to the activities they want to do.
6 In their initial submittal, obviously, with 7
30 years of safe store, it didn't go into a lot of detail.
8 But they subsequently provided information when they 9
went began active decommissioning and the other actions 10 they've taken. They also have to provide a cite for the 11 cost estimate.
12 Additionally, they have to
- submit, 13 annually, financial reports on their expenditures and 14 status of the decommissioning trust fund. So we 15 maintain continual observation of their trust fund and 16 progress of decommissioning. And that's what the union 17 share when they send it in.
18 The next step in the process is the License 19 Termination Plan. When -- at least two years prior to 20 completion of the decommissioning, when they want to have 21 the license terminated, they need to submit a License 22 Termination Plan. We'll go into some more detail on 23 that. And that's the focus of that meeting as they have 24 now submitted that plan.
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After the License Termination Plan is 1
approved and they complete the decommissioning, they 2
will then begin a final set of surveys where they're going 3
to survey the site to determine if they have 4
decommissioned it if compliance with the plan and to the 5
levels we require. And after that is done, we would then 6
be terminating the license.
7 Our regulations are specific in certain 8
aspects of decommissioning, such that they cannot do any 9
activities that would not allow the release of the site 10 for unrestricted use, so they wouldn't be able to 11 terminate the site and release it completely, not result 12 in any environmental impacts that were not previously 13 considered. Environmental evaluations were performed 14 for licensing of the site and operation of the facility, 15 and they cannot do any actions through decommissioning 16 that would cause any impacts beyond what had previously 17 been evaluated.
18 They also cannot take any actions through 19 decommissioning that result in there not being 20 sufficient funds to complete the decommissioning. And 21 that's part of why we monitor the funding annually.
22 The focus during decommissioning is on 23 these primary areas, the removal of the facility from 24 service, the reduction of radioactive materials to the 25
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level that allows us to terminate the license, and 1
detailed radiological surveys of the site they conduct 2
and confirmatory surveys that we'll be conducting.
3 This is an outline of what the LTP needs to 4
include. Pacific Gas & Electric will go into more detail 5
on the content of the License Termination Plan, but I just 6
wanted to give a sort of overview of what the LTP is.
7 It's essentially a document that is an agreement with us 8
as to how they're going to cleanup the site to meet our 9
release criteria, how they're going to do the surveys to 10 prove that they've cleaned up the site sufficiently.
11 Our release criteria is dose based. The 12 regulations state that following decommissioning the 13 residual plant-generated radiological materials cannot 14 contribute more than 25 millirems per year dose to an 15 individual. To put that in context, the average person 16 in the United States is exposed to approximately 350 17 millirems per year from background radiation.
18 The 25 millirem per year is based on a dose 19 modeling that has to be done. They'll go into it -- the 20 licensee will go into it in a little more detail. But 21 the dose modeling process assumes that there's going to 22 be an individual, in this case, it's called a resident 23 farmer scenario, who, following the license termination, 24 would choose to establish his residence an farm on the 25
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site. They have to analyze all the pathways by which 1
that individual could be exposed to the residual 2
radioactive material, determine what level of radiation 3
can be left that would limit the dose of that person to 4
25 millirems per year, and then they would do the surveys 5
to confirm that the level that is actually left is less 6
than that analyzed level.
7 So it's fairly complicated, but it 8
basically models the dose so they can take a radiation 9
measurement of the site to the surveys and know that 10 there's little enough material left that the dose would 11 not exceed that 25 millirem per year.
12 This is basically the review process for the 13 License Termination Plan. As Bruce mentioned, we've 14 already completed our acceptance review. That's 15 basically just the look at the License Termination Plan 16 to insure they included all the required information and 17 it appears to have enough substance for a technical 18 review.
19 Second step is our technical review. We 20 have done that now. Typically, it takes about a year.
21 Frequently, it also requires some questions. I don't 22 believe we've ever had a License Termination Plan where 23 we didn't have some questions on it. So we would have 24 a request for additional information to be provided to 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 10 get whatever additional information we needed.
1 We are required to have a public meeting.
2 That's why we're here today. We also have an opportunity 3
for comment from the public, and it's not just at this 4
meeting tonight. When we get to the end of my slides, 5
my e-mail address will be listed there. If anybody wants 6
more information on the License Termination Plan, if 7
anybody wants to provide comments on the License 8
Termination Plan, you can contact me at any time during 9
our review process. It's not -- it doesn't just have to 10 be tonight.
11 Assuming the License Termination Plan is 12 reviewed and determined to be acceptable, it is approved 13 by a license amendment. The reason for that is it then 14 becomes part of the facility's license. They have to 15 comply with the plan with exceptions that may be noted.
16 But it is not a -- it's a somewhat inflexible document.
17 They have certain aspects they have to comply with as they 18 completed the decommissioning. And NRC, during the 19 process, will also perform inspections of what's going 20 on and confer with the facility.
21 This is the latter part of the survey of the 22 process through the License Termination Plan. As they 23 get near the end of their termination process, they will 24 be submitting final status surveys. This is where they 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 11 would go out, conduct radiological surveys of any kind 1
of structures if there were any structures left, 2
although, Humboldt is not planning on leaving any 3
standing; they will conduct surveys of the soil in areas 4
that are going to be released in the license, all with 5
the intent of showing that they've met the cleanup 6
criteria that was established in the plan.
7 The NRC would review and approve those final 8
status survey reports, confirming that they are meet our 9
expectations for detail and the data is the kind of 10 numbers we would need. We also have contractors from Oak 11 Ridge who would come in and do confirmatory surveys 12 because we want to have independent eyes come in and do 13 the same surveys to verify that their surveys were 14 actually performed adequately. And assuming both their 15 surveys and our surveys show that the site has been 16 decontaminated to the appropriate levels, the license 17 would then be terminated.
18 This is the contact information. Anybody, 19 if you want to jot down the e-mail address, if you want 20 to contact either myself or Blair at the regional office, 21 any questions either on the License Termination Plan or 22 any aspects of the decommissioning process, either now 23 or later, be happy to hear from you.
24 And the point at the bottom bullet there, 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 12 we have an electronic meeting room available on the 1
Internet. You can access the License Termination Plan 2
there, if you want to. It is available in our ADAMS 3
system. If you have any trouble finding that, you can 4
ask me. And I think I even have about eight copies of 5
it on CD, so if somebody wants a copy tonight, I'll be 6
happy to give it to you.
7 MR. WATSON: Thank you, John.
8 Loren, you're next.
9 MR. SHARP: So we're going to give you a 10 little status of where we're starting the License 11 Termination Plan from, where we've achieved our actual 12 decommissioning to date, and we'll go ahead and provide 13 a little bit of the status of what we've accomplished so 14 far. And then Bill will give you a little bit more update 15 on exactly what we've done with the License Termination 16 Plan.
17 So the line in yellow outlines all the 18 property that is under the Part 50 license at Humboldt 19 Bay. So we will have to clean up and remediate all the 20 property inside of that line in order to get acceptable 21 relief and termination of the license from the NRC.
22 This slide shows a little bit of the 23 overview of the site. Again, this is where the Unit 3 24 structure is. This is where Units 1 and 2 used to be 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 13 before we demolished those. And we'll finish 1
the -- based on those that were done with the lay down 2
the area.
3 This shows the infrastructure that we put 4
in place in the 2009 and '10 time frame. We put in 5
trailers for housing the office personnel. We put in a 6
road for access as well as the scales and truck portal.
7 And we also put in a radiological access building in 2010.
8 This photo shows exactly what our status is 9
right now at this point. This shows how it was 10 constructed, ground level being at this level plus 12.
11 This is roughly minus 66 below grade. This area shows 12 the actual reactor vessel, the reactor dry well, the 13 bio-shield wall and the outer caisson.
14 What's important to note about the reactor 15 vessel is everything inside of the reactor vessel has 16 been removed. We have removed all the reactor 17 internals; we have drained the reactor vessel; and we are 18 in the process right now of removing the control drive 19 mechanisms underneath the vessel. Once we've completed 20 with that, we'll go into the reactor vessel segmentation.
21 This shows some of the items that we have, 22 indeed, removed from the reactor vessel and as well as 23 the spent fuel pool. We took out the spent fuel pool 24 racks after we sent the dry cask storage up the hill with 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 14 the fuel in them in 2008.
1 In the upper right, the control rod blades 2
were put into a shield cask and we then moved them over 3
into a pool. We actually shipped out -- there are two 4
shipments of control rod blades. The first one went out 5
yesterday, and the second shipment will go out next week 6
to Texas.
7 This is the main steam line we removed from 8
the reactor head space. And then this is the lower core 9
shroud that we cut up and removed. It's been shipped to 10 Texas in some of our B and C waste shipments.
11 The yellow diagram shows the location of 12 what we're going to install as a slurry wall. And we'll 13 show a few more details of that in a minute. We're going 14 to put a slurry wall down to minus 170 foot elevation so 15 we can protect the ocean from the site as we go after 16 removal of the structures down below grade.
17 This shows a little bit of how that slurry 18 wall will work. We essentially would end up putting down 19 a slurry wall down to the clay layer, which is minus 170.
20 And this portion, although not depicted accurately, this 21 is like minus 80. And we would remove the water down to 22 like minus 80.
23 And when we get to that point, then we can 24 start taking apart the infrastructure that's 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 15 underground. And after we've got the slurry walls 1
installed by this type of machine, and then we would 2
remove the infrastructure. So that's kind of how the 3
slurry wall goes in to allow us to take this structure 4
out. It's commonly used in construction of plants near 5
water bodies to make sure they can construct them.
6 Now I'll turn it over to Bill.
7 MR. BARLEY: All right. Go into a little 8
bit about what is specifically in our License Termination 9
Plan. As John Hickman talked about, the process that we 10 have is -- and exactly where we are right now in the 11 process is up here. As you can see, we submitted our plan 12 on May 3rd. It has been through the NRC acceptance 13 review. And we have the public meeting tonight. And we 14 anticipate that the review will be completed sometime out 15 in next year.
16 I'll go through the different chapters that 17 we have. We have eight chapters in the LTP. The first 18 chapter is pretty much a summary of the history of the 19 site that defines the years that it operated, some of the 20 problems that we had over the years, just a running 21 scenario of that reactor operation that occurred back in 22 those days.
23 And also, it addresses a little bit of an 24 overview of what the rest of the chapters contain. So 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 16 as a "pick it up and read it" document, this is one you 1
might want to look at and just get a feel for what's in 2
the overall document.
3 The second chapter is where we have 4
assembled all of the characterization data that was done 5
so that we could plan our decommissioning. By 6
assembling all the different radiological information 7
that we had, we could then go off and plan the details 8
that we'll see in the rest of this document. So this 9
chapter presents that summary in a very easy-to-read 10 format. For people who are familiar, they'll be able to 11 use that in their review as they look at the rest of our 12 document to assess whether or not our plans are adequate 13 for going forward with the rest of our decommissioning.
14 Chapter 3, then, looks at, where are we in 15 the decommissioning process, because we've been at this 16 for a few years already. What we've done, at a very high 17 level at this point because we're still working out some 18 of the minor details going forward. But at a high level, 19 we've laid out those activities that we still have to do, 20 like Loren talked about for installation of the slurry 21 wall, the removal of the caisson and large structures 22 like that that we have on-site, in addition to the final 23 status survey that was just done and other 24 end-of-the-document reports writing we have to do.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 17 Chapter 4, then, presents all the different 1
processes that we may be using in order to remediate the 2
site and get down to that release level that John talked 3
about. So we have to get down to the 25 millirem to that 4
individual in any one year. And this lays out all those 5
various processes that we have at our disposal that we 6
will be using throughout the decommissioning process.
7 Chapter 5, then, lays out our plans for 8
doing this final status survey. How will we do all of 9
these various surveys to accumulate the data that the NRC 10 is going to need to assess that, yes, we do meet that final 11 clearance criteria at the end when we want to terminate 12 the license. It lays out exactly how we're going to 13 survey the units, how we're going to assess the data that 14 we get back, how our data quality requirements form that 15 data. So a lot of detail in here that lays out 16 specifically how that program will work so they can 17 review that in detail and ensure themselves that, yes, 18 we've laid out a good plan to get forward to accumulate 19 the data that they're going to need to terminate the 20 license.
21 Chapter 6 is where we get into his 22 discussion about how did we come up with that clearance 23 criteria. So of all the chapters, this is the most 24 technical, challenging one to get through. We use 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 18 various computer programs that are approved. We develop 1
site-specific criteria that we input to that program and, 2
through that, develop a level at which we must get to to 3
demonstrate compliance with that end state. And this 4
will probably be one that Karen will spend a lot of time 5
with looking at and getting back to us.
6 Chapter 7, then, goes into the funding 7
requirements for the site. So here we have laid out 8
exactly what we see as the required funding to complete 9
the rest of the decommissioning and what our plans are 10 for that, to assess that funding to get us to the end 11 state.
12 And again, the NRC will look at that and say, 13 does this look reasonable? So every step along the way, 14 they'll be reviewing this submittal that we give to them 15 to ensure that we haven't missed something, have them ask 16 us questions, and we'll be giving them additional 17 information in this area as more is developed.
18 And then, finally, Chapter 8. We talked 19 about -- John talked about the fact that we have to look 20 at, we're not going to do any environmental degradation 21 above the plans that we already had in place. So what 22 we've had to do is look at all the various things that 23 we're going to be doing the rest of the project and assess 24 them against the general criteria for decommissioning 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 19 plants that's out there and to assure ourselves and the 1
NRC that it's within all of the expected environmental 2
problems that we would expect to see in another 3
decommissioning plant somewhere.
4 And I think, with that, I turn it over to 5
Blair next.
6 MR. SPITZBERG: Good evening.
7 My name is Blair Spitzberg. And I'm from 8
the Region IV office of the NRC. Most people think that 9
NRC being in Washington D.C. and our headquarters is near 10 Washington D.C. in Rockville, but we have four regional 11 offices.
12 And ours happens to be geographically the 13 largest, is the western half of the United States 14 basically. And we do all the inspections of licensees 15 that NRC licenses within all of those states. And we go 16 out as far as Hawaii and Alaska and American Samoa and 17 Guam and a couple of other small places out west. But 18 we do cover a large area.
19 And our office is in Arlington, Texas, which 20 most of you probably know is between Dallas and Fort 21 Worth, and we're very close to the airport. So we have 22 the ability to get on planes and come out to sites on short 23 notice. Fortunately, we don't have to do that often.
24 But one of our responsibilities is event response. If 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 20 there was an event or an accident or something that we 1
needed to come out and look into fairly rapidly, we are 2
able to do that.
3 The way we regulate decommissioning 4
basically is fairly straightforward. I think most of 5
you would be able to come up with the same criteria that 6
we use to regulate. We establish and ensure adherence 7
to the requirements which are contained fundamentally in 8
the regulations. Title 10 of our regulations is where 9
most of our requirements are, but we also rely on 10 regulations from EPA and OSHA that we also have a role 11 in enforcing, Department of Transportation.
12 And then we also have a whole collection of 13 safety standards that we issue, ourselves. And some of 14 them are safety standards that we rely on other aspects 15 of the safety community to establish the standards that 16 we, then, commit our licensees to through the license.
17 And then the license is active until license termination.
18 And it contains license conditions and technical 19 specifications. And so those establish the criteria 20 that we inspect against.
21 What we're here tonight for is the License 22 Termination Plan which was just submitted recently. And 23 this is the second aspect of how we regulate safety, is 24 performing licensing reviews and safety evaluations. And 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 21 that's what John is talking about, that this is going to 1
be a process by which they'll be performing the technical 2
review of the License Termination Plan. Once this 3
License Termination Plan is in place and approved, then 4
we will inspect against that License Termination Plan and 5
all the commitments that the licensee has made in that 6
plan.
7 And finally, the way that we ensure safety 8
is by performing inspections and taking enforcement when 9
necessary. And that's what the regional offices do, for 10 the most part. We send inspectors out to the sites on 11 a regular basis, and we do rather invasive inspections.
12 And most of our inspections are a announced, but some of 13 them can be unannounced. We can carry a multitude of 14 inspectors who have different expertise in different 15 areas. I have a number of inspectors who are specialists 16 in the decommissioning arena, but if we need somebody 17 that is a specialist in another technical area, whether 18 it's health physics or environmental monitoring or in the 19 case of -- believe it or not, in some cases in 20 decommissioning, there's construction that takes place, 21 for example, the slurry wall that they're planning to put 22 in place here. We'll probably have to have some 23 inspectors with a different background and expertise 24 come out and look at the installation of the slurry wall.
25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 22 So just let me cover the types of 1
inspections that we do and have been doing for years since 2
Humboldt Bay shut down permanently. We do regular 3
decommissioning inspections out there. That's my staff 4
that does that. And we quite often will have folks from 5
our headquarters office accompany us on those 6
inspections.
7 And we generally try and schedule these 8
inspections during periods of activity that we consider 9
to have a higher risk associated with it. So if they're 10 removing a large component or if they're cutting a piece 11 of a facility that may have become highly activated 12 during the years of operation, or if they're moving some 13 spent fuel or some radioactive waste, something that may 14 be of a slightly higher risk than the normal routine 15 decommissioning activities, that's what we try to target 16 our inspections around and -- so that we can come out and 17 look at that activity and also look at the training and 18 the records and everything associated with that and doing 19 independent measurements. And we'll go through all 20 these inspection procedures, but I wanted to convey the 21 fact that we do try to -- because I have a limited staff, 22 to try and target our inspections for those higher-risk 23 activities.
24 The other inspection arena that we do out 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 23 here is this acronym called ISFSI, independent spent fuel 1
storage installation. For those of you who don't know, 2
the majority of the fuel that was used at Humboldt Bay 3
is still on-site, but it has been removed from the spent 4
fuel pool and put in what we call dry casks. And they're 5
specifically licensed for the dry casks at this site.
6 And it will remain in the dry cask until the federal 7
government establishes a repository for this fuel to be 8
sent to.
9 And so the good news that this spent fuel 10 is all in dry casks; it's out of the pool so that they 11 can now dismantle their spent fuel pool. And I have 12 inspectors on my staff that do ISFSI routine inspections 13 and will continue to do this beyond when the Part 50, the 14 reactor license is terminated in few years.
15 And we also have physical security 16 inspections that are performed by a different group 17 within the region and they come out an perform specific 18 inspections on the security systems at the site.
19 So what is it we try and do during the 20 inspection? We try and verify whether there's -- when 21 the licensee is conducting their activities safely and 22 in compliance with the license. We try and verify 23 whether there's adequate licensee controls on their 24 processes, whether they have procedures in place for all 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 24 of the processes that they're undertaking, whether they 1
have reviewed and approved the procedures and the 2
procedure changes that are required to effectively and 3
safely implement those activities. We ensure safety 4
problems and violations are promptly identified and 5
corrected and that effective corrective action is taken 6
to prevent recurrence. And then we also, for periods of 7
time, we examine trends in licensee safety and 8
performance.
9 This list, I'm not going to go through the 10 whole list, but this is a list of our core inspection 11 procedures that we utilize during the decommissioning 12 process. And if you look at this, it covers just about 13 everything. We get down into -- for example, they have 14 to have an organization that meets what they committed 15 to in their License Termination Plan or in their license.
16 So if they don't have the specific personnel staff in 17 positions that are important to safety, for example, like 18 whether they have operators or radiation safety folks, 19 health physics
- folks, environmental monitoring 20 specialists, they have to have those positions filled.
21 And so we look that those positions are filled by 22 qualified individuals.
23 And we look at the safety reviews, the 24 design changes and the modifications that they make to 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 25 their facilities and their procedures. We look at their 1
self-assessments and their quantity assurance audits and 2
their corrective action program.
3 I mentioned that we do separate independent 4
spent fuel storage installation inspections, so we do 5
look at the safety of the fuel as it's being stored. We 6
look at the occupational radiation exposure, the final 7
status surveys. We do surveys throughout the 8
decommissioning process.
9 My inspectors are all health physicists, 10 and they're well-trained and they have a bevy of 11 instruments that we bring out to the site to do 12 independent surveys. And then we also have a contractors 13 laboratory in Oak Ridge that we also have come out at 14 various times during the decommissioning process to do 15 verification surveys.
16 At the end of this process when the 17 licensees tells us that they're ready, that they've met 18 the release criteria for the site, we'll do extensive 19 surveys at that time using our contractor laboratory to 20 verify that. But we do it in process as well.
21 We also look at radwaste treatment, 22 effluent monitoring and environmental monitoring. We 23 look at transportation when we move materials. We were 24 just looking at packaging of a waste package today, or 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 26 yesterday when we arrived. We look at maintenance and 1
surveillance and, as I mentioned, physical security. And 2
also look at their contingency procedures and processes.
3 Okay. So what we do with these inspections 4
once we complete them? We're a public agency. We owe 5
the public the information that -- on how we regulate.
6 And we think we do a pretty good job of trying to 7
communicate that, this meeting being one example. But 8
we communicate with the public every day on our website, 9
nrc.gov.
10 And for the most part, with few exceptions, 11 all of our inspection reports are publicly available. The 12 only ones that are normally not publicly available are 13 the ones that speak to physical security issues that 14 we -- that our physical security inspectors look at.
15 Their reports are -- portions of them are public. But 16 any sensitive information having to do with the physical 17 security systems in place at the site would not be made 18 public for obvious reasons.
19 But our decommissioning inspection reports 20 are all made publicly available, and they're all 21 available on our website. And we hope that you would 22 take advantage and look at them from time to time to keep 23 an eye on how we're looking after activities at the site.
24 One of the things we also do is we coordinate 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 27 with the program office, Bruce's office. He's got a group 1
of license reviewers and experts in Washington in the 2
decommissioning arena, and I have the inspectors, so we 3
talk all the time back and forth between our office in 4
Arlington and their office in Washington to help us 5
refine and determine how best to perform our inspections, 6
what activities to look at. And we coordinate quite 7
extensively with them.
8 We normally will send out an inspection 9
schedule with them at least a year in advance. We don't 10 always adhere to the dates on the schedule, but we do try 11 and conduct the number of inspections that we plan to 12 conduct. And as I mentioned, they quite often will come 13 out with us. And we'll adjust the schedule during the 14 year as needed and based upon licensee activities and 15 balancing our inspection schedule out here with our 16 inspections that are needed at some of the other plants 17 where there's maybe a higher-risk activity occurring at 18 the same time.
19 In order to plan and execute the inspection, 20 as I mentioned, they could be announced; they could be 21 unannounced. We find that usually there's merit in 22 announcing our inspections if we're looking at a specific 23 area. We want to make sure that the people are going to 24 be there that we need to talk with.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 28 But we're also able to do inspections, and 1
we do do inspections that are unannounced. And 2
sometimes we do an unannounced inspection for the benefit 3
of following up on, for example, on allegations, 4
something like that, where we need to talk to somebody 5
or somebody may have contacted us and we need to go out 6
and look after a concern that they have.
7 Breach inspection is an inspection plan 8
that's developed. And that comes to me for approval. And 9
we'll talk about what that particular inspection will 10 cover and come to an agreement on that. And we'll sign 11 off on the inspection plan before it's executed.
12 And then after the inspection, the 13 inspector will hold an exit meeting with the 14 licensee -- normally at the end of the week; it can be 15 done telephonically when they get back to the regional 16 office, but normally it's at the end of week -- where we 17 brief the licensees on our preliminary findings. And 18 this is where we would identify any potential violations 19 that are identified, whether the licensees is in 20 compliance, whether there's any follow-up issues.
21 Then when the inspector comes back to the 22 office, he will debrief before the management in the 23 Region IV office, and we'll quite often have the 24 headquarters folks come, and say what the findings are.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 29 And we'll make an agency determination of what the 1
findings are. And then based on that, the inspector will 2
go back and write his or her report and will issue that 3
report.
4 Down at the bottom of the slide, most of our 5
inspection reports are issued within 30 days. If we have 6
a team inspection, we're given a 45-day window to 7
complete the inspection report because it involves more 8
inspector input, and they're usually more lengthy 9
reports.
10 I put up there the location where you can 11 find our enforcement policy. If there are violations, 12 we have a very well-defined enforcement policy on how we 13 treat the violations. As you might expect, the 14 violations will be treated based upon their 15 significance, and so we have different categories.
16 Depending upon what category the violation is identified 17 in, whether it's in health physics or transportation or 18 management organization, quality assurance, whatever 19 the category it's in, we have a supplement to our 20 enforcement policy that defines what the significance of 21 the violation would be.
22 And then based upon that, we'll determine 23 whether or not we issue a notice of violation to the 24 licensee or whether we can document the violation in the 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 30 report. For those cases where the violations are more 1
significant, we have other options available. We can 2
have enforcement conferences with the licensees; we can 3
issue monetary civil penalties; we can modify the 4
license; we can issue orders. There's a whole 5
assortment of enforcement tools available to us.
6 The good news is that we very seldom have 7
to implement that because, for the most part, the 8
licensees that we regulate are good, in compliant 9
licensees. And we don't often find significant 10 violations, but we do on occasion. And when we do, we 11 have the tools available to us to take the necessary 12 enforcement to prevent recurrence.
13 And then finally, at the end of the 14 inspection process, we also keep a list of things we need 15 to follow-up on in future inspections so that we will not 16 let issues drop that we need to come back and look at again 17 and again and again.
18 Okay. So I've already talked about what 19 happens after the inspection, so I think I've covered 20 what's on this slide.
21 I just want to mention where you can find 22 our inspection reports. If you go to the website here 23 in this slide at nrc.gov, the ADAMS webpage, you can look 24 up inspection reports by docket number. And I don't 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 31 recall the docket number off the top of my head. But if 1
any of you want to ask that at the end -- oh, it's up there.
2 05000133 is the docket number. And if you look under 3
that, you'll be able to find all of our safety inspection 4
reports.
5 Okay. So how many inspections do we do?
6 Normally, right now we're doing about one a quarter. But 7
as I mentioned, as activity at the site dictate, you know, 8
we'll send inspectors out for the critical activities.
9 But we have been, for the last couple years, been doing 10 somewhere between four and six inspections a year, about 11 one a quarter.
12 Inspections typically last a full week that 13 we're onsite. And they can consist of one or more 14 inspectors. Quite often, they'll consist of at least 15 two inspectors. But this week, for example, we were 16 conducting an inspection. And Rob Evans out here in the 17 audience is one of my senior inspectors, and he's 18 conducting inspections this week.
19 Talked about enforcement. We have a 20 categorization of severity levels for the violations 21 that we identify. Anything that's Severity Level 3 or 22 above is considered escalated enforcement. There's 23 been one case of escalated enforcement in recent years 24 out here. It did involve a security matter that I can't 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 32 talk about tonight. But it with a Severity Level 3, so 1
it was just in the category that we consider for escalated 2
enforcement, but it wasn't the highest category. And 3
that's been taken care of and resolved. Otherwise, we 4
have a good recent enforcement history with this licensee 5
going back to the start of the decommissioning work.
6 And then I put my coordinates up there. If 7
anybody would like to call me, I'd welcome you to call 8
me or to send me an e-mail. If you have any questions, 9
I'll be glad to get back with you. And also my division 10 director, Tony Vegel, his address is up there. And our 11 Region IV main switchboard number is up there as well.
12 So please avail yourself of those numbers if you'd like 13 to get in touch with the inspection office in Region IV, 14 we welcome that.
15 So with that, turn it back to Bruce.
16 MR. WATSON: It's question and answer time, 17 or question and comment time. Does anybody have any 18 comments? Or would you like to take a five-, ten-minute 19 break and then we'll start?
20 No?
21 Like I said, we do have complete sheets in 22 the back. We would like you to complete those. You can 23 just put those in the post to us, or you can leave them 24 with us. There's also some index cards back there that 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 33 if you want to write a question down and pass them up, 1
we'll be happy to respond to those also.
2 Yes, sir?
3 MR. ENNIS: I'd like to make some comments.
4 MR. WATSON: Can you state your name for us, 5
please?
6 MR. ENNIS: Yes. My name is Michael Ennis.
7 I moved to Humboldt County in 1964, a couple years after 8
the power plant went into operation.
9 And I spent 31 years as an engineer, the last 10 at 21 at Humboldt State University in the Department of 11 Environmental Engineering. And I taught environmental 12 science, environmental issues, energy issues. And 13 consequently, I was very well-versed with not only the 14 nuclear power plant but also with fossil fuel units and 15 pretty much all the energy stuff we're doing here in the 16 county.
17 In 1987 when the
- final, I
- guess, 18 environmental impact statement was issued, I taught a 19 class at Humboldt State, I had 36 students, on 20 decommissioning nuclear power plants. And it was a real 21 eye-opener for me. I never worked harder in all my life 22 and learned so much in a short period of time. But I 23 learned a lot and met a lot of people. And I think my 24 qualifications as someone to speak about nuclear power 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 34 are kind of there.
1 I retired from teaching in 2003. And since 2
1998, I've been on the Community Advisory Board and 3
working very closely with PG&E, and obviously aware of 4
why we're here today.
5 I just want to give you a little bit of 6
background about Humboldt County. We're a pretty unique 7
place. Aside from our notorious reputation, this is a 8
relatively small county that is made up of some very 9
unique, talented, wonderful, wonderful people. And we 10 take our environment very, very seriously. Everything 11 from, in the '60s, when Redwood National Park was formed, 12 everything from the infamous headwater forests that was, 13 again, nationwide news. If you step outside one your 14 way, you'll see a shell of one of the two pulp mills that 15 were basically shut down because they couldn't meet the 16 regulatory standards. We're active in toxic sprays on 17 our forests. I mean, the list goes on and on and on.
18 The variety of people here care about their 19 environment. And our most treasured and our most 20 precious piece of the environment is Humboldt Bay. And 21 we find that, not only is it an ecological treasure, we 22 have a national wildlife refuge; we have a variety of 23 state and local preserves, Arcata Marsh, if you have a 24 chance to go up there. We see the Bay as an important 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 35 resource for commerce. And we hope to, at some point, 1
expand shipping through here, but we also have fisheries, 2
we have oyster fisheries.
3 And probably the most important thing that 4
we have is the recreation on Humboldt Bay. All kinds of 5
trails, all kinds of access, and you can go out anytime 6
of the week and you will find people basically using that.
7 So this brings us to the nuclear power 8
plant. For basically 50 years, the residents of 9
Humboldt County have lived with the -- whatever words we 10 want to use, the fear, the concern, the issue of safety 11 in terms of the power plant, earthquakes, tsunamis. If 12 you were here in June of 1992 we had three separate 7.0 13 earthquakes in a 24-hour period. Pretty wild.
14 The plant operated 14 years. Science 15 Magazine, in 1972, called it the dirtiest plant in the 16 nation. We remember that. The spent fuel has been in 17 a pool for a long, long time. And luckily enough it is 18 now in a secure -- I feel very confident. I worked with 19 PG&E in terms of getting this ISFSI up. And I feel that 20 it is the best possible solution in terms of earthquakes 21 an tsunamis. And I hope that it will last for a long time 22 because they may have to last a very long time. And yet 23 we still live with this fear and this concern that there 24 is spent fuel that's here and may be here for a long period 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 36 of time.
1 The final thing, cleaning up the site. And 2
again, with the advisory committee, we spent a lot of time 3
talking about this, how clean is it, you know? How all 4
those acronyms, all those things that, you know, you deal 5
with on an everyday basis, it all boils down to us, the 6
residents of Humboldt County, looking out on this bay and 7
saying, "This is a treasure." And that site has to be 8
cleaned up to the utmost.
9 And I think that the plan that PG&E has come 10 up with, basically, meets that. And so therefore, I want 11 to ask you, I guess, want you to assure the public that 12 you, as the NRC, the final ruling on the decision, you 13 have the ultimate say that you basically give us the words 14 that we've lived with for so many years, that nuclear 15 power is clean, safe, and cheap. At least you can live 16 up to part of that mantra.
17 Thank you.
18 MR. WATSON: I guess I'll just add a couple 19 of comments, and thank you for your comments.
20 Our limitation is, our criteria are this 25 21 millirem per year. And it also includes the concept of 22 ALARA. And like I said, we have terminated the licenses 23 at eleven reactors so far. Seven of those have been 24 under our current regulations. And with each one of 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 37 those, those terminations were conducted and completed 1
with rigorous inspections, rigorous blind sampling, 2
split sampling, confirmatory surveys.
3 And the results of those terminations were 4
that, in reality, the actual criteria were well-met and 5
were only a few fractions -- a small fraction, I should 6
say, of the 25 millirems when the licensee completed the 7
termination of the license. And like I said before, we 8
will not terminate any license until the licensee 9
demonstrates to us that they have complied with the 10 license termination criteria. And we're there to verify 11 it all the way to the end.
12 Any other questions? Comments?
13 State your name please.
14 MR. BOHN: I'm Rex Bohn. I've lived here 15 since the '50s. I haven't lived here in quite as much 16 fear, but I've lived within two or three miles as the crow 17 flies, since I was a pup.
18 I'm the first district supervisor of 19 Humboldt County and vice-chair. And we submitted a 20 letter to the Nuclear Regulatory Commission, and on 21 behalf of the Humboldt County Board of Supervisors, we 22 support the Humboldt Bay Power Plant License Termination 23 Plan that was recently submitted for your consideration 24 by Pacific Gas & Electric.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 38 The plan submitted is a well-thought-out 1
approach to addressing the challenges of decommissioning 2
the former nuclear power generation station in a manner 3
that is safe for the local community and the environment.
4 It goes on to say that we have full faith 5
in the plan that has been brought forth. I think the 6
citizens -- I'm also on the Citizens Advisory Committee.
7 I'm newer on the Citizens Advisory Committee, but I think 8
the plan that PG&E has brought forth, the transparency, 9
and especially what they've done to the community to 10 relieve the fears, and maybe that's why I haven't had 11 these fears. And it may be just lack of education, or 12 it may be I've got bigger things to worry about, and I 13 don't know what they are right now.
14 But I'm saying, as we move forward, I would 15 love to give full trust and full power to the powers that 16 be, you guys, to let this proceed. Loren and his team, 17 I don't know how many community meetings we had. And I 18 think -- I was up there today, and they're doing water 19 sampling on the channels at the request of the citizens 20 and working with the citizens on that. So I compliment 21 PG&E.
22 The Board of Supervisors ratify in this 23 letter that you got on a 5-0 vote. They have appeared 24 in front of the Board many times to explain what they are 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 39 doing. And at the drop of a hat, they will do it at any 1
other time. So again, the Board of Supervisors 2
appreciates Humboldt County. And I appreciate the job 3
they're doing for our citizens.
4 Thank you.
5 MR. WATSON: Thank you for the comments.
6 Appreciate that.
7 I think one of processes that the NRC 8
promotes is having the community involved in the 9
decommissioning process. We entrusted the utility to 10 operate the plant for the number of years that they chose 11 to operate it, and we expect them to also safely 12 decommission the plant. And part of that is getting the 13 community involved so they understand what is going on 14 and what activities are going to be conducted at the site 15 so that they can convey to everybody in the community how 16 those things are done and how it's important that they 17 are done safely.
18 Do we have any other comments, questions?
19 Come on up. Can you state your name, 20 please?
21 MS. HALL: Jessica Hall, I'm a Humboldt 22 Baykeeper. So I understand that you can't talk about the 23 specifics of the violation that you described, or one of 24 you described, but I'm curious to know what the reasons 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 40 were that you couldn't share the details of that.
1 And you talk about the recent history of the 2
decommissioning process being -- going on very safely.
3 If you have any reflections on what happened prior to 4
that, I would also love to hear that.
5 MR. HICKMAN: Let me speak first to the 6
security violations. One of the aspects of nuclear 7
safety that we're responsible for ensuring is the 8
security of nuclear materials. And that includes 9
nuclear materials that are possessed or generated by 10 nuclear power plants, of which Humboldt Bay is one and 11 they have nuclear materials. They have to have a 12 physical security plan that we approve to safeguard the 13 nuclear materials in their possession. And we perform 14 inspections of the physical security plans.
15 Some of the requirements of the physical 16 security plans are that when a licensee violates any 17 aspect of that physical security plan, depending upon 18 what the violation is, they have to notify us. I don't 19 remember exactly the time frame. This was a couple years 20 ago. They notified us that they had violated an aspect 21 of a physical security plan.
22 And that's about as much as I can say about 23 what the violation was. But I just wanted to explain the 24 context of how we regulate the physical security 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 41 activities at the site and what they pertain to.
1 The second question was, I think, the 2
inspection record going back over time. You're racking 3
my brain now. We did have -- there was another case of 4
escalated enforcement back around ten years ago. And 5
that was something that we held public meetings out here 6
on, and we interacted with the public when they 7
were -- when Humboldt Bay was doing a full assessment of 8
all the fuel and the forms of the fuel that they had in 9
their spent fuel pool.
10 And they had a discrepancy in their records 11 that indicated that a small portion of a their fuel -- of 12 a fuel rod was unaccounted for. So as a result of that, 13 the licensee went into an exhaustive search where they 14 went through every little piece of everything that was 15 in there spent fuel pool; they examined all over the 16 plant; they looked at all their historical records of 17 what may or may not have been shipped off as waste and 18 so forth.
19 And they came out with a set of scenarios 20 that explained what the potential pathways for this were.
21 And we agreed with that, in effect; but as a result of 22 that, even though they went through this exhaustive 23 investigation, we concluded that they had lost 24 accountability for this small amount of spent fuel rod.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 42 And as a result of that, there was a civil penalty that 1
was about --
2 I don't remember, Dave, do you remember?
3 It was about ten years ago. Yeah. Since that time, you 4
know, as far as the decommissioning activities at the 5
site, we've not identified any significant violations 6
that had risen to the point of us taking escalated 7
measures.
8 Did that answer your question?
9 MS. HALL: Yes. Thank you.
10 MR.
WATSON:
Additional questions?
11 Please feel free.
12 PARTICIPANT: Maybe I can get just, like, 13 a show of hands, I'd like to see how many people are here 14 from the public, and not the NRC and PG&E.
15 So public people? We're overwhelmed.
16 Thank you.
17 MR. WATSON: Well, hearing no other 18 questions, I just thought I'd make a couple closing 19 remarks. And I'll go back up to the podium for that.
20 Again, let me thank you for attending and 21 providing your comments. In closing, I want to 22 emphasize three points.
23 The NRC will be here to ensure that Humboldt 24 Bay completes the decommissioning safely and securely.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 43 We will only terminate the license when they demonstrate 1
to us that they have met all the site criteria and the 2
site regulations for ensuring that the site meets our 3
criteria for terminating the license. We will continue 4
our inspections of Humboldt Bay all the way to the end, 5
and actually, inspections will continue with the ISFSI 6
afterwards.
7 We have begun our initial review of the 8
license termination plan. We expect that this detailed 9
technical review will take approximately a year. So 10 again, we would ask you if you have any comments, you can 11 go to our website, you can e-mail John or Blair or myself 12 with any comments you have on the LTP. And we look 13 forward to hearing any additional comments you may have 14 that if you do take the time to look at the LTP, it is 15 fairly extensive as it's intended to be. It's fairly 16 technical. And we look forward to any comments that you 17 may have. So I appreciate you coming tonight. And 18 thank you very much.
19 (Whereupon, the above-entitled matter 20 concluded at 7:05 p.m.)
21 22 23 24 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 44 1