ML15351A463
| ML15351A463 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 12/17/2015 |
| From: | Ray Kellar Division of Nuclear Materials Safety IV |
| To: | Halpin E Pacific Gas & Electric Co |
| ray kellar | |
| References | |
| IR 2015010 | |
| Download: ML15351A463 (16) | |
See also: IR 05000133/2015010
Text
E. Halpin -2-
Should you have any questions concerning this inspection, please contact Dr. Gerald
Schlapper, Health Physicist, at 817-200-1273 or the undersigned at 817-200-1191.
Sincerely,
/RA R. Browder for/
Ray L. Kellar, P. E., Chief
Fuel Cycle and Decommissioning Branch
Division of Nuclear Materials Safety
Docket No: 050-00133
License No: DPR-7
Enclosure:
NRC Inspection Report 050-00133/15-010
X SUNSI Review ADAMS X Publicly Available X Non-Sensitive
By: GAS X Yes No Non-Publicly Available Sensitive
OFFICE RIV/DNMS/FCDB FCDB C/FCDB
NAME DLStearns GASchlapper RLKellar
SIGNATURE /RA/E-Schlapper /RA/ /RA/RBrowder
for
DATE 12/15/15 12/15/15 12/17/15
DISTRIBUTION:
Mark Shaffer, D:DNMS
Linda Howell DD:DNMS
Michael Vasquez, C:NMSB:A
Jack Whitten, C:NMSB:B
Bruce Watson, C:NMSS/DDURWP/RDB
Cindy Rosales-Cooper, RIV ETA
Angel Moreno, Congressional Affairs Officer
John Hickman, NMSS/DDURWP/RDB
Rachel Browder, FCDB
Robert Evans, FCDB
Gerald Schlapper, FCDB
Donald Stearns, FCDB
Marisa Herrera, Fee Coordinator, DRMA
Thomas R. Baldwin, Regulatory Services
Manager, Diablo Canyon and Humboldt Bay
Power Plant
Pacific Gas and Electric Company
P.O. Box 56
Avila Beach, CA 93424
Jennifer L. Post, Esq.
Pacific Gas and Electric Company
P.O. Box 7442
San Francisco, CA 94120
Loren Sharp, Director and Plant Manager
Humboldt Bay Power Plant, PG&E
1000 King Salmon Avenue
Eureka, CA 95505
Chairman
Humboldt County Board of Supervisors
County Courthouse
825 Fifth Street
Eureka, CA 95501
Law Office of Linda J. Brown, Esq.
999 5th Avenue, Suite 430
San Rafael, CA 94901
Regional Radiation Representative
U.S. Environmental Protection Agency
Region IX Office
75 Hawthorne Street
San Francisco, CA 94105
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Dr. James F. Davis, State Geologist
Department of Conservation
Division of Mines and Geology
801 K Street MS 12-30
Sacramento, CA 95814-3531
Director, Radiologic Health Branch
State Department of Health Services
P.O. Box 997414 (MS 7610)
Sacramento, CA 95899-7474
Gretchen Dumas, Esq.
Public Utilities Commission
of the State of California
5066 State Building
San Francisco, CA 94102
Director
Energy Facilities Siting Division
Energy Resources Conservation
& Development Commission
1516 9th Street
Sacramento, CA 95814
Redwood Alliance
P.O. Box 293
Arcata, CA 95521
Dr. Robert B. Weisenmiller, Chair
California Energy Commission
1516 Ninth Street (MS 34)
Sacramento, CA 95814
California Public Utilities Commission
505 Van Ness, Room 4102
San Francisco, CA 94102
Deputy Attorney General
State of California
110 West A Street, Suite 700
San Diego, CA 92101
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U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 050-00133
License: DPR-7
Report: 050-00133/15-010
Licensee: Pacific Gas and Electric Company
Facility: Humboldt Bay Power Plant, Unit 3
Location: 1000 King Salmon Avenue
Eureka, California 95503
Dates: October 27-29, 2015
Inspector: Gerald A. Schlapper, PhD, CHP, Health Physicist
Fuel Cycle and Decommissioning Branch
Donald L. Stearns, Health Physicist, Inspector
Fuel Cycle and Decommissioning Branch
Approved by: Ray L. Kellar, P. E., Chief
Fuel Cycle and Decommissioning Branch
Division of Nuclear Material Safety
Enclosure
EXECUTIVE SUMMARY
Humboldt Bay Power Plant, Unit 3
NRC Inspection Report 050-00133/15-010
This inspection was a routine, announced inspection of decommissioning activities being
conducted at the Humboldt Bay Power Plant (HBPP), Unit 3 facility. In summary, the
licensee was conducting site activities in compliance with regulatory and license
requirements.
Safety Reviews, Design Changes and Modifications
The licensee continued to conduct safety reviews by the Plant Safety Review Committee
(PSRC). The committee continued its review of design changes and modifications to
include where applicable procedural changes. (Section 1.2)
Self-Assessment, Auditing, and Corrective Action
The licensee conducted audits, self-assessments and corrective actions in accordance
with procedures and regulatory requirements. (Section 2.2)
Maintenance and Surveillance
The licensee maintained adequate radiation protection instrumentation for conduct of
decommissioning activities. Status of decommissioning activities has eliminated the
need for the stack monitor system. (Section 3.2)
Decommissioning Performance and Status Review
The licensee conducted decommissioning activities in accordance with license and
regulatory requirements. (Section 4.2)
Solid Radioactive Waste Management and Transportation of Radioactive Materials
The licensee conducted solid waste management and transportation activities in
accordance with procedures and regulatory requirements. A minor concern was noted
related to inclusion of documentation with a limited number of shipments. (Section 5.2)
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REPORT DETAILS
Summary of Plant Status - Unit 3
At the time of the inspection, the licensee continued to conduct decommissioning of
remaining structures and areas around the site, including equipment removal, building
demolition, and excavation. Decommissioning was performed in accordance with the
general guidance provided in the Post-Shutdown Decommissioning Activities Report
(PSDAR) dated July 19, 2013, (ADAMS Accession No. ML13213A160).
A License Termination Plan (LTP) was submitted to the U.S. Nuclear Regulatory
Commission (NRC) on May 3, 2013, and was followed with submittals in response to
NRC requests for additional information (ML131300009, ML131300160). On August 13,
2014, LTP Revision 1, which included information based on the above submittals, was
submitted (ML14246A164). This plan will further define the site remediation process and
the final status surveys used to demonstrate unrestricted use of the site and to support
license termination. In addition, the plan will refine decommissioning cost estimates and
thereby provide a detailed baseline for cost and schedule considerations.
The contractor for the civil works portion of the decommissioning, Chicago Bridge and
Iron (CB&I), continues to prepare the remaining portions of the reactor building and the
spent fuel building for demolition. All segments of the pressure vessel, including the
lower head and the upper vessel flange, have been removed from the reactor building
and shipped to a waste site for burial. The licensee continues to transport other waste to
appropriate disposal sites. The licensee continues the process of analyzing the
feasibility and cost associated with removal of subsurface structures as part of the
decommissioning process.
1 Safety Reviews, Design Changes, and Modifications (37801)
1.1 Inspection Scope
The inspector evaluated the licensees program of safety reviews to ensure that
the program is effective. The inspector also reviewed facility design changes and
modifications.
1.2 Observations
The inspector reviewed the current organizational structure of the licensee and the
primary support contractor. As work changes from self-directed activities to
licensee oversight of contractor-supervision activities, then emphasis on certain
functions will change. For example, as radioactive material is removed and dose
rates are reduced to background levels, the licensee plans to make significant
changes in the radiation protection program. By the end of the year the licensee
has determined that access control will no longer be required and personal
dosimeters will no longer be issued. Area badges will be employed to estimate
potential for employee exposure. The licensee has already placed area monitoring
dosimeters in appropriate locations and has accumulated data for two quarters of
operation. Results of these measurements were reviewed by the inspector who
noted that all results were essentially at background levels and hence future
exposures, if any, would be a small fraction of the dose limits for occupational
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workers and monitoring would no longer be required. In addition, there will no
longer be a need for radiation work permits. As a result, training will be scaled
back to some degree since there will be less need for emphasis on protection from
alpha contamination and potential for internal and external exposures. The
reduced requirements in the radiation protection area is reflected in a projected
decrease in radiation protection staffing by the end of 2015.
The inspectors reviewed actions by the Plant Staff Review Committee (PSRC) as
outlined in minutes of the committees meetings. The inspectors also attended a
meeting of the PSRC that was held during the period of the inspection.
Establishment of a quorum of qualified individuals was noted. The meetings were
initiated with a safety message, related to the rapidly changing conditions at the
site. Much of the discussion related to the transfer of responsibilities and
requirements from the Unit 3 Part 50 license to the ISFSI Part 72 license. Impacts
in Emergency Planning and Procedures and Quality Assurance programs were
noted. Committee action and approval was timely as the licensee needs to
complete actions no later than December 22, 2015 to meet implementation
deadlines of the NRC approved License Amendment Request (LAR).
The Humboldt Bay Power Plant Quality Assurance Plan (QAP) addresses
requirements of the Humboldt Bay Unit 3 Part 50 License and the Independent
Spent Fuel Storage Installation (ISFSI) Part 72 License. By letter dated June 10,
2014, (ML14176A080) the licensee submitted revision 32 to the QAP, which
changed the oversight of the QA Program from the Nuclear Safety Oversight
Committee (NSOC) to a requirement for an Independent Management Review
function. In response to a request from NRC, the licensee submitted additional
information by letter dated August 15, 2014 (ML14227A958). The NRC approved
the request for change to QAP on September 4, 2014 (ML14238A627).
Implementation of the change is through Procedure HBAP, Independent
Management Review, effective September 4, 2014 that notes that the Chief
Nuclear Officer is responsible for designating the reviewer(s) to assess the
effectiveness of the QAP and other appropriate oversight activities at the site. The
licensee is committed to conducting an effectiveness review at a minimum of every
2 years. The inspector noted that as of the dates of the inspection a review had
not been conducted and the reviewer(s) had not been appointed. The appointment
of a qualified reviewer and conduct of the review will be of continuing interest in
future inspections.
1.3 Conclusions
The inspector concluded that there is adequately trained and qualified staff to
conduct decommissioning activities at the site. The inspector reviewed the
program for conduct of management safety reviews in light of changes to the
Humboldt Bay QAP and found them to meet regulatory requirements.
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2 Self-Assessment, Auditing and Corrective Action (40801)
2.1 Inspection Scope
The inspector reviewed the licensees program for self-assessment, conduct of
audits and continuation of corrective actions.
2.2 Observations
The inspector reviewed a quality verification short form assessment of the
Special Nuclear Material (SNM) Inventory process (Assessment No. 15274002).
This assessment addressed the physical inventory of spent fuel and reactor
related Greater Than Class C (GTCC) waste currently stored at the Humboldt
Bay ISFSI. The licensees assessment identified that the inventory was
conducted in accordance with approved procedures and the requirements
outlined in 10 CFR 72 and the ISFSI FSAR Section 5.3 were met. The licensees
review noted that training and qualification of personnel was adequate to satisfy
Regulatory and Licensing requirements; however, the procedural requirements
impose a certification requirement on a broader group of reviewers than is
required by regulation. Also discussed in the assessment was the fact that the
procedure does not clearly define the requirements for certification. The
inspector noted that the review was conducted within the allowed time limit of
12 months and that quality verification staff observed conduct of the inventory.
The inspector also selected for review an audit of the License Termination Plan
(LTP) Final Status Survey (FSS) Quality Program requirements, File No.
150910023, that addressed the period April 7 through July 9, 2015. At the time
of review by the licensee, the LTP was still under review by the NRC and as
such, this review was initiated in order to assess readiness. The audit noted that
while implementation of the program is effective overall, there is a need for a
higher level of rigor in implementation of some programs. Areas for improvement
were suggested in definition of training and qualification requirements, consistent
implementation of administrative and quality program requirements and the
impact of changes to plans and procedures. The audit noted that the program is
fundamentally sound and that corrective actions to address the issues identified
in the audit will facilitate the integration of requirements, administrative programs,
implementing procedures and organizational structure. The inspector noted that
the audit results contained a detailed list of deficiencies that were updated and
tracked in the licensees corrective action program.
With the change of programs and procedures associated with reassignment of
responsibilities related the Unit 3 Part 50 license to the ISFSI Part 72 license, the
site is involved with changes to its emergency plan, fire protection, quality
assurance and access control programs. The inspector verified that the quality
verification team was working to ensure timeliness of documentation of the
program changes. The inspector noted in discussion with management and staff
at the site that effort was required to ensure that procedural requirements were in
line with organizational changes. The inspector noted that management was
aware of the need for timely implementation and continued review and
assessment of programs.
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2.3 Conclusion
The inspector concluded that self-assessment programs and the conduct of
audits complied with license and regulatory requirements.
3 Maintenance and Surveillance (62801)
3.1 Inspection Scope
The inspectors reviewed calibration and maintenance of the Main Plant Exhaust
Fan (MPEF) and Stack Particulate Airborne Monitoring System (SPAMS). This
system was removed from service on October 14, 2015, and physically removed
from the plant in order to allow demolition of plant structures and installation of
the Cutter Soil Mixture (CSM) wall. The inspectors also reviewed data supplied
through the calibration database for portable radiation survey instruments.
3.2 Observations
The Main Plant Exhaust System and the SPAMS was the last plant system
remaining in operation. All other plant systems have been shut down and
removed from the buildings where they were located. The inspectors reviewed
the status of SPAMS to ensure that the system continued to perform its function
until the end of service. SPAMS was a continuous alpha-beta monitor system
installed in the main plant exhaust duct and monitored gaseous release to the
environment. The system allowed for collection of particulate on filter paper for
subsequent isotopic analysis. The inspectors reviewed documentation of the
analysis of these filters along with the most recent calibration of the monitor,
which was performed on October 6, 2015. The analysis and calibration were
found to have been performed in accordance with plant procedures.
Removal of the reactor pressure vessel, contaminated piping and components in
the drywell allowed the licensee to attain a radioactive source term reduction that
showed, through a calculation of exposure potential that was reviewed by the
inspector, that open air demolition could be conducted. Since the exhaust
system was no longer necessary, the system and monitoring equipment were
removed from service on October 14, 2015, the date that the licensee began
open air demolition of the eastern portion of the reactor and refuel building.
The licensee has a continuing need for use of portable radiation survey
instruments. The inspectors reviewed survey instrument data through use of the
calibration database for these instruments. Per procedure, the licensee uses
color coding to track calibration due dates in the database. For example an
instrument calibrated and in use is coded green. Once the instrument is due for
calibration within 30 days, a yellow flag is coded in the database. If past due for
calibration, the database entry is red flagged. This approach provides for quick
assessment of instruments in the database. Instrument calibration is no longer
performed on site. The instruments are either sent to a licensed vendor for
calibration or to the NRC licensed program at the Diablo Canyon Nuclear Station
for calibration.
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3.3 Conclusions
The inspectors noted that the licensees program for maintenance and calibration
of the Main Plant Exhaust Fan and associated monitor system (SPAMS) were in
compliance with applicable procedures and regulatory requirements. The
inspectors also noted that through use of the calibration database and checks in
the field of selected instruments that the instruments in use were within
calibration dates. The inspectors validated that there were an adequate number
and type of instruments for radiation protection requirements during
decommissioning activities.
4 Decommissioning Performance and Status Review (71801)
4.1 Inspection Scope
The inspector evaluated whether the licensee and its contracted workforce were
conducting decommissioning activities in accordance with license and regulatory
requirements.
4.2 Observations
Primary efforts for the remaining months of calendar year 2015 are to complete
asbestos abatement for the exterior of the reactor and spent fuel buildings in
preparation for demolition of the buildings, placement of clean excavated material
into the discharge canal, removal of the remaining components that contain
residual radioactivity, continued installation of the CSM wall, and transport of
construction debris to proper burial sites.
At the time of the inspection, installation of panels of the CSM wall was
temporarily on hold due to a requirement to remove structures that prevented
operation of the installation equipment. Each panel is approximately three feet
wide and nine feet long and of varying depth. The CSM wall is constructed of
5 rings (A through E) with the outer E ring of depth that cuts into the clay layer
and acts to cut off water flowing into the area below the reactor caisson. Soon
after completion of the inspection, installation of the CSM wall sections resumed.
Of the approximately 250 wall sections that are required, 76 sections had been
completed by late November and completion of the wall is anticipated during the
second quarter of 2016.
Demolition of the interior of the liquid waste building, and demolition of tunnels
and piping connecting it to the reactor building was complete, including the
Secondary Alarm Station (SAS) structure and associated off-gas tunnel. The
concrete floor, concrete north wall still remain intact. The removal of the liquid
waste building metal shell was completed on schedule. The solid waste building
located just north of the liquid waste building has been demolished. The
concrete floor of the solid waste building remained at the time of inspection and
will be removed at a later date.
The discharge canal has been isolated from the bay. The removal of the rip rap
material along the sides of the canal has been completed, with the exception of
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the material at the extreme southern end of the canal. Ground water slowly
seeps into the southern end of the discharge canal and is processed through a
treatment system prior to allowing discharge to the bay. The Ground Water
Treatment System (GWTS) is in the process of being expanded in anticipation of
need for additional capacity. All excavated material including the rip rap material
and material from the CSM wall is monitored for radioactivity prior to reuse or
disposal.
The inspectors reviewed the setup and use of the detector system used to
monitor trucks of excavated material. The system is composed of four detectors.
Two detectors each are located in enclosed trailers on either side of a set of
scales for the dump trucks hauling the material. The system, known as the
Guardian System, has been calibrated to accommodate a variety of containers
and trucks loaded with the excavated material. The volume and weight of
material in the truck is measured to determine the density of the material. This
parameter is entered into the counting system along with the type of truck and
the trucks empty weight. Typically a 1000 second count is performed to
determine the concentration of activity of the material in the truck. Once the
count survey is completed, then the material is placed into the discharge canal at
locations that have been previously declared and verified to be clean per Final
Status Survey criteria. The licensee provided data that showed that through the
end of October, 646 truckloads containing approximately 10,300 tons of soil had
been placed in the canal location.
4.3 Conclusions
The licensee conducted decommissioning activities in accordance with license
and regulatory requirements.
5 Solid Radioactive Waste Management and Transportation of Radioactive
Materials (86750)
5.1 Inspection Scope
The inspector reviewed documentation associated with shipments of material to
their respective burial sites. The shipments included solid waste shipments by
truck of exempt material to a site approved for Resource Conservation and
Recovery Act (RCRA) in Idaho, low specific activity solid waste shipment to a
Utah burial site approved for low specific activity radioactive waste, and
shipments utilizing a combination of truck and rail transport of low specific activity
waste to Waste Control Specialists (WCS) in Texas. The review included
documentation required by Department of Transportation regulations, and
documentation of waste classification required by 10 CFR Part 20. The
inspectors also verified that the licensee had the required import and export
licenses for shipment and acceptance of the material.
5.2 Observations
To ensure compliance with applicable NRC and Department of Transportation (DOT)
regulations, the licensee utilized a shipping compliance checklist. The checklist
requires that the licensee have documentation on file to certify that any container
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used meets package qualifications and that vendor provided procedures for use of
the container were followed. The package qualification includes documentation that
manifested information is consistent with the approved waste profile. Documents
supplied in the package indicated that the container had been inspected by the
licensee and determined to be in compliance with DOT packaging requirements.
Radiation/contamination survey data sheets were noted that verified compliance with
applicable limits as outlined in 10 CFR 71.47. Emergency response information was
supplied with all shipments. Required direct radiation and contamination surveys
verified compliance with DOT packaging requirements. A vehicle inspection
checklist was completed prior to approval for the vehicle to depart the site. A review
of documents for these selected shipments indicated that license and regulatory
requirements were met. Prior to departure, a signature by the licensee, in its
oversight role, is required to verify that all documents associated with the shipment
have been completed in accordance with licensee procedures and that the material
is packaged, characterized, classified, marked, labeled, placarded and transported in
accordance with regulatory requirements of NRC and the DOT.
Beginning on September 2, 2015, the licensee began a trial program to evaluate the
acceptability of shipping to an additional burial site. Specifically, shipments of low
specific activity material to Waste Control Specialists (WCS) in Andrews, Texas. For
each shipment to WCS, a total of 5 truck shipments are sent from Humboldt Bay to
Redding, California, to a rail yard. At that point, the 5 truck loads are consolidated
into a rail car and one shipment is made from Redding to the WCS site in Texas.
Proper transportation and waste classification documentation accompanied the
shipments from Redding, California, to the WCS burial site near Andrews, Texas.
From January 1, 2015, through October 26, 2015, the licensee made a total of 744
shipments to the various burial sites with a total volume of 288,971 cubic feet. Of the
744 shipments made, 645 shipments went to the US Ecology site in Idaho, 58
shipments were sent to the Energy Solutions site in Utah and 14 shipments were
directed to the WCS site in Texas.
5.3 Conclusions
The licensees program for transportation of solid waste material for off-site burial
was found to be performed in accordance with license and regulatory
requirements with one minor concern that was corrected during the period of the
inspection.
6 Exit Meeting
The inspectors reviewed the scope and preliminary findings of the inspection
during an exit meeting that was conducted at the conclusion of the onsite
inspection on October 29, 2015, with a follow up telephonic exit on November 19,
2015. The follow up telephonic exit was to further discuss the five truck
shipments that were consolidated to one rail shipment. The licensee did not
identify as proprietary any information provided to, or reviewed, by the
inspectors.
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SUPPLEMENTAL INSPECTION INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
K. Rod, Decommissioning Manager
L. Sharp, Director and Plant Manager
M. Strehlow, Deputy Director
W. Barley, RP Consultant and FSS Supervisor
J. Chadwick, ALARA Supervisor
P. Coutts, CBI Program Manager
M. Erickson, FSS and LTP Engineer
E. Kahler, Engineering Manager
S. Jones, QV Supervisor
D. LeBoeuf, CBI Deputy Program Manager
W. Parish, RP Engineer
B. Rittmer, ISFSI Manager
K. Rowberry, Acting RP Manager
J. Salmon, Environmental Manager
D. Sokolsky, Licensing Consultant
INSPECTION PROCEDURES (IP) USED
IP 37801 Safety Reviews, Design Changes and Modifications at Permanently
Shutdown Reactors
IP 40801 Self-Assessment, Auditing, and Corrective Action at Permanently
Shutdown Reactors
IP 62801 Maintenance and Surveillance at Permanently Shutdown Reactors
IP 71801 Decommissioning Performance and Status Review at Permanently
Shutdown Reactors
IP 86750 Solid Waste Management and Transportation of Radioactive Materials
Attachment
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Closed
None
Discussed
None
LIST OF ACRONYMS
ADAMS Agencywide Documents Access and Management System
CAP Corrective Action Program
CB&I Chicago Bridge & Ironworks
CFR Code of Federal Regulation
CSM Cutter Soil Mixture
DOT Department of Transportation
FSS Final Site Survey
HBPP Humboldt Bay Power Plant
IP NRC Inspection Procedure
ISFSI Independent Spent Fuel Storage Installation
LTP License Termination Plan
NRC U.S. Nuclear Regulatory Commission
QAP Quality Assurance Plan
RWP Radiation Work Permit
RCRA Resource Conservation and Recovery Act
SFP Spent Fuel Pool
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