IR 05000133/2007003: Difference between revisions
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| issue date = 08/03/2007 | | issue date = 08/03/2007 | ||
| title = IR 05000133-07-003, on 07/10/2007 - 07/13/2007, Humboldt Bay Power Plant, Unit 3 | | title = IR 05000133-07-003, on 07/10/2007 - 07/13/2007, Humboldt Bay Power Plant, Unit 3 | ||
| author name = Spitzberg D | | author name = Spitzberg D | ||
| author affiliation = NRC/RGN-IV/DNMS/FCDB | | author affiliation = NRC/RGN-IV/DNMS/FCDB | ||
| addressee name = Keenan J | | addressee name = Keenan J | ||
| addressee affiliation = Pacific Gas & Electric Co | | addressee affiliation = Pacific Gas & Electric Co | ||
| docket = 05000133 | | docket = 05000133 | ||
| Line 18: | Line 18: | ||
=Text= | =Text= | ||
{{#Wiki_filter | {{#Wiki_filter:August 3, 2007Mr. John Senior Vice President - Generation and Chief Nuclear Officer Pacific Gas and Electric Company P.O. Box 770000, Mail Code B32San Francisco, California 94177-0001 SUBJECT:NRC INSPECTION REPORT 050-00133/07-003 | ||
SUBJECT: NRC INSPECTION REPORT 050-00133/07-003 | |||
==Dear Mr. Keenan:== | ==Dear Mr. Keenan:== | ||
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Garcia at (530) 756-3910. | Garcia at (530) 756-3910. | ||
Sincerely,/RA/D. Blair Spitzberg, Ph.D., ChiefFuel Cycle and Decommissioning BranchDocket No.: 050-00133License No.: DPR-7 | Sincerely, | ||
/RA/D. Blair Spitzberg, Ph.D., ChiefFuel Cycle and Decommissioning BranchDocket No.: 050-00133License No.: DPR-7 | |||
===Enclosure:=== | ===Enclosure:=== | ||
NRC Inspection Report 050-00133/07-003 Pacific Gas and Electric Company - 2 - | NRC Inspection Report 050-00133/07-003 Pacific Gas and Electric Company - 2 - | ||
REGION IV Docket No.:050-00133License No.:DPR-7 Report No.:050-00133/07-003 Licensee:Pacific Gas and Electric Company (PG&E) | |||
Supplemental Inspection Information ADAMS Entry:IR 05000133-07-03, on 07/09-13/07; Pacific Gas & Electric Co.;Humboldt Bay, Unit 3. No Violations. | Facility:Humboldt Bay Power Plant (HBPP), Unit 3Location:1000 King Salmon AvenueEureka, California 95503Dates:July 10 - 13, 2007 Inspector:Emilio M. Garcia, Health PhysicistFuel Cycle and Decommissioning Branch, Region IVAccompanied by:John B. Hickman, Project ManagerReactor Decommissioning Branch, Office of Federal and StateMaterials and Environmental Management ProgramsThomas H. Youngblood, Jr., Health PhysicistReactor Decommissioning Branch, Office of Federal and StateMaterials and Environmental Management ProgramsApproved By:D. Blair Spitzberg, Ph.D., ChiefFuel Cycle and Decommissioning Branch, Region IVAttachments:Supplemental Inspection Information ADAMS Entry:IR 05000133-07-03, on 07/09-13/07; Pacific Gas & Electric Co.;Humboldt Bay, Unit 3. No Violations. | ||
-2-EXECUTIVE SUMMARYHumboldt Bay Power Plant, Unit 3NRC Inspection Report 050-00133/07-003The Humboldt Bay Power Plant (HBPP), Unit 3 was shutdown in 1976. The facility has been ina SAFSTOR status since shutdown with minimal decommissioning activity. This routineinspection was conducted to review the licensee's organization and management controls,safety reviews, design changes and modifications, spent fuel pool safety, maintenance andsurveillance, decommissioning performance, occupational radiation exposures, and radioactivewaste treatment, effluent and environmental monitoring.Organization, Management and Cost Controls*The licensee had sufficient staff to conduct the work in progress, including an amplenumber of certified fuel handlers. The onsite review committee was functioning inaccordance with quality assurance program requirements. The composition,organization and charter of the offsite review committee were under review at the time ofthe inspection. The offsite review committee had yet to meet in 2007 (Section 1).Safety Reviews, Design Changes, and Modification*The licensee's safety review program was conducted in compliance with 10 CFR 50.59requirements. The licensee had established and implemented a non-conformanceprogram that was in compliance with Quality Assurance Plan requirements (Section 2).Spent Fuel Pool Safety*The licensee was maintaining the SFP water level and water chemistry in accordancewith Technical Specifications requirements and Defueled Safety Analysis Reportcommitments (Section 3).Maintenance and Surveillance*The licensee had implemented a maintenance program which met the requirements ofthe Maintenance Rule provided in 10 CFR 50.65 (Section 4). Decommissioning Performance and Status Review*Radiological conditions of the facility were properly posted. Housekeeping and facilityconditions were effectively controlled (Section 5). | -2-EXECUTIVE SUMMARYHumboldt Bay Power Plant, Unit 3NRC Inspection Report 050-00133/07-003The Humboldt Bay Power Plant (HBPP), Unit 3 was shutdown in 1976. The facility has been ina SAFSTOR status since shutdown with minimal decommissioning activity. This routineinspection was conducted to review the licensee's organization and management controls,safety reviews, design changes and modifications, spent fuel pool safety, maintenance andsurveillance, decommissioning performance, occupational radiation exposures, and radioactivewaste treatment, effluent and environmental monitoring.Organization, Management and Cost Controls*The licensee had sufficient staff to conduct the work in progress, including an amplenumber of certified fuel handlers. The onsite review committee was functioning inaccordance with quality assurance program requirements. The composition,organization and charter of the offsite review committee were under review at the time ofthe inspection. The offsite review committee had yet to meet in 2007 (Section 1).Safety Reviews, Design Changes, and Modification*The licensee's safety review program was conducted in compliance with 10 CFR 50.59requirements. The licensee had established and implemented a non-conformanceprogram that was in compliance with Quality Assurance Plan requirements (Section 2).Spent Fuel Pool Safety*The licensee was maintaining the SFP water level and water chemistry in accordancewith Technical Specifications requirements and Defueled Safety Analysis Reportcommitments (Section 3).Maintenance and Surveillance*The licensee had implemented a maintenance program which met the requirements ofthe Maintenance Rule provided in 10 CFR 50.65 (Section 4). Decommissioning Performance and Status Review*Radiological conditions of the facility were properly posted. Housekeeping and facilityconditions were effectively controlled (Section 5). | ||
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-5- b.Onsite and Offfsite Review CommitteesThe Quality Assurance Plan, Revision 20, provides the requirements for the Plant StaffReview Committee (PSRC) and the Nuclear Safety Oversight Committee (NSOC). Theinspector reviewed the implementation of the committees to ensure compliance withquality assurance program requirements. The PSRC was the onsite group that reviewed proposed changes, tests andexperiments, plant modifications, procedure revisions, and other issues having nuclearsafety significance. As of July 11, 2007, the PSRC had met 19 times during 2007. Theinspector reviewed the PSRC meeting minutes from March to June 2007. Minutesdocumented that the quorum requirements had been met and provided a list of allsubjects reviewed. The committee reviewed and approved, as appropriate, proposedprocedure changes, temporary procedures, plant modifications, negative trends, andnonconformances. Reasons were documented when proposed changes or procedureswere rejected by the committee.The NSOC provided high level review and oversight of site activities including the PSRC. The NSOC was required to meet at least twice per year. The only site person that was amember of this committee was the plant manager. The committee had not yet met in2007. The Licensing Supervisor stated that the composition, organization and charter ofthe NSOC were under review at the time of the inspection. Although no meeting wasscheduled, the Licensing Supervisor expected that the first meeting of the year wouldoccur in September.1.3ConclusionsThe licensee had sufficient staff to conduct the work in progress, including an amplenumber of certified fuel handlers. The onsite review committee was functioning inaccordance with quality assurance program requirements. The composition,organization and charter of the offsite review committee were under review at the time ofthe inspection. The offsite review committee had yet to meet in 2007.2.0Safety Reviews, Design Changes, and Modifications (37801) | -5- b.Onsite and Offfsite Review CommitteesThe Quality Assurance Plan, Revision 20, provides the requirements for the Plant StaffReview Committee (PSRC) and the Nuclear Safety Oversight Committee (NSOC). Theinspector reviewed the implementation of the committees to ensure compliance withquality assurance program requirements. The PSRC was the onsite group that reviewed proposed changes, tests andexperiments, plant modifications, procedure revisions, and other issues having nuclearsafety significance. As of July 11, 2007, the PSRC had met 19 times during 2007. Theinspector reviewed the PSRC meeting minutes from March to June 2007. Minutesdocumented that the quorum requirements had been met and provided a list of allsubjects reviewed. The committee reviewed and approved, as appropriate, proposedprocedure changes, temporary procedures, plant modifications, negative trends, andnonconformances. Reasons were documented when proposed changes or procedureswere rejected by the committee.The NSOC provided high level review and oversight of site activities including the PSRC. The NSOC was required to meet at least twice per year. The only site person that was amember of this committee was the plant manager. The committee had not yet met in2007. The Licensing Supervisor stated that the composition, organization and charter ofthe NSOC were under review at the time of the inspection. Although no meeting wasscheduled, the Licensing Supervisor expected that the first meeting of the year wouldoccur in September.1.3ConclusionsThe licensee had sufficient staff to conduct the work in progress, including an amplenumber of certified fuel handlers. The onsite review committee was functioning inaccordance with quality assurance program requirements. The composition,organization and charter of the offsite review committee were under review at the time ofthe inspection. The offsite review committee had yet to meet in 2007.2.0Safety Reviews, Design Changes, and Modifications (37801) | ||
2.1Inspection ScopeThe inspector conducted reviews of the licensee's design change and nonconformanceprograms to ensure compliance with the requirements of 10 CFR 50.59 and QualityAssurance Plan requirements. 2.2Observations and Findings a.Design Change ProcessLicensee procedure HBAP C-19, "Licensing Basis Impact Evaluation (LBIE),"Revision 21, establishes the requirements for evaluating potential effects on licensingbasis documents from proposed changes to the facility, procedures, te st or ex periments. This procedure was used to determine if 10 CFR 50.59 evaluations were required and | 2.1Inspection ScopeThe inspector conducted reviews of the licensee's design change and nonconformanceprograms to ensure compliance with the requirements of 10 CFR 50.59 and QualityAssurance Plan requirements. 2.2Observations and Findings a.Design Change ProcessLicensee procedure HBAP C-19, "Licensing Basis Impact Evaluation (LBIE),"Revision 21, establishes the requirements for evaluating potential effects on licensingbasis documents from proposed changes to the facility, procedures, te st or ex periments. This procedure was used to determine if 10 CFR 50.59 evaluations were required and-6-whether prior NRC approval was required before implementing the changes. Theinspector reviewed selected design change packages to ascertain whether the changesincluded a safety review or safety screening and adequate explanation of the changebeing proposed. The inspector reviewed five design change notices issued since thisarea was last inspected in March 2007. Each package included a safety screen thatincluded consideration of the requirements of 10 CFR 50.59. Other attributesconsidered included impacts on decommissioning and whether changes were requiredto be implemented in licensing basis documents, site procedures, and site drawings. Allsafety screens were complete. None of the changes involved a full safety evaluation. Further, the design change notices provided sufficient detail to explain what was being changed. b.Nonconformance ReportsSection 3.1.4 of the Quality Assurance Plan states that measures shall be establishedfor documenting, reviewing, and dispositioning of quality problems and non-conformances. During 2006, four non-conformance reports (NCRs) were opened. TheNCRs were discussed in inspection report 05000133/2006003. No additional NCRs hadbeen opened. At the time of this inspection, two of the 2006 NCRs remained openpending completion of corrective actions to prevent recurrence (CAPR). NCR 06-04 had been initiated by the previous Plant Manager to evaluate and resolve anapparent weakness in the standard test procedure scheduling process. This NCR wasprovided for closure evaluation to on June 2007 and returned to the plant on June 27,2007, because the documented corrective actions did not reflect the actions taken andother actions were incomplete. NCR 06-02 relates to what the licensee originallycharacterized as an unexplained significant increase in the liquid radioactive waste tankactivity. At the time of the inspection, the quality verification staff was reviewing thisNCR to verify closure of all required actions.2.3ConclusionsThe licensee's safety review program was conducted in compliance with 10 CFR 50.59requirements. The licensee had established and implemented a non-conformanceprogram that was in compliance with Quality Assurance Plan requirements.3.0Spent Fuel Pool Safety (60801) | ||
-6-whether prior NRC approval was required before implementing the changes. Theinspector reviewed selected design change packages to ascertain whether the changesincluded a safety review or safety screening and adequate explanation of the changebeing proposed. The inspector reviewed five design change notices issued since thisarea was last inspected in March 2007. Each package included a safety screen thatincluded consideration of the requirements of 10 CFR 50.59. Other attributesconsidered included impacts on decommissioning and whether changes were requiredto be implemented in licensing basis documents, site procedures, and site drawings. Allsafety screens were complete. None of the changes involved a full safety evaluation. Further, the design change notices provided sufficient detail to explain what was being changed. b.Nonconformance ReportsSection 3.1.4 of the Quality Assurance Plan states that measures shall be establishedfor documenting, reviewing, and dispositioning of quality problems and non-conformances. During 2006, four non-conformance reports (NCRs) were opened. TheNCRs were discussed in inspection report 05000133/2006003. No additional NCRs hadbeen opened. At the time of this inspection, two of the 2006 NCRs remained openpending completion of corrective actions to prevent recurrence (CAPR). NCR 06-04 had been initiated by the previous Plant Manager to evaluate and resolve anapparent weakness in the standard test procedure scheduling process. This NCR wasprovided for closure evaluation to on June 2007 and returned to the plant on June 27,2007, because the documented corrective actions did not reflect the actions taken andother actions were incomplete. NCR 06-02 relates to what the licensee originallycharacterized as an unexplained significant increase in the liquid radioactive waste tankactivity. At the time of the inspection, the quality verification staff was reviewing thisNCR to verify closure of all required actions.2.3ConclusionsThe licensee's safety review program was conducted in compliance with 10 CFR 50.59requirements. The licensee had established and implemented a non-conformanceprogram that was in compliance with Quality Assurance Plan requirements.3.0Spent Fuel Pool Safety (60801) | 3.1Inspection ScopeThe inspector reviewed the licensee's control of the SFP to ensure compliance withTechnical Specifications requirements and Defueled Safety Analysis Report (DSAR)commitments. 3.2Observations and FindingsThe inspector conducted a tour of the SFP area and reviewed plant records to ensurethe safe storage of the fuel and other irradiated items in the pool. TechnicalSpecifications 3.1.1 states that the SFP water level shall be at an elevation of greater-7-than 10.5 feet. At the time of the inspection, the water level was 10.80 feet. Theinspector also confirmed that the low water level alarm was set at 10.67 feet as requiredby the DSAR.Technical Specifications 3.1.3 states that the SFP liner water level shall be at anelevation less than +9 inches (0.75 feet). The liner water level was -0.04 feet during theinspection. The inspector also confirmed that the licensee was monitoring both SFPlevel and liner water level at the frequencies established in Technical Specificationssurveillance requirements.To prevent inadvertent drainage of the SFP, the licensee had sealed the stop valve onthe SFP drain, removed the piping beyond the stop valve and placed a blind flange onthe pipe stem. On July 11, 2007, the inspector toured the pipe gallery area and verifiedthat these were the conditions of SFP drain. The inspector also verified that procedureHBAP C-9 #1 listed the SFP drain stop valve as a sealed or locked valve. | ||
3.1Inspection ScopeThe inspector reviewed the licensee's control of the SFP to ensure compliance withTechnical Specifications requirements and Defueled Safety Analysis Report (DSAR)commitments. 3.2Observations and FindingsThe inspector conducted a tour of the SFP area and reviewed plant records to ensurethe safe storage of the fuel and other irradiated items in the pool. TechnicalSpecifications 3.1.1 states that the SFP water level shall be at an elevation of greater | |||
-7-than 10.5 feet. At the time of the inspection, the water level was 10.80 feet. Theinspector also confirmed that the low water level alarm was set at 10.67 feet as requiredby the DSAR.Technical Specifications 3.1.3 states that the SFP liner water level shall be at anelevation less than +9 inches (0.75 feet). The liner water level was -0.04 feet during theinspection. The inspector also confirmed that the licensee was monitoring both SFPlevel and liner water level at the frequencies established in Technical Specificationssurveillance requirements.To prevent inadvertent drainage of the SFP, the licensee had sealed the stop valve onthe SFP drain, removed the piping beyond the stop valve and placed a blind flange onthe pipe stem. On July 11, 2007, the inspector toured the pipe gallery area and verifiedthat these were the conditions of SFP drain. The inspector also verified that procedureHBAP C-9 #1 listed the SFP drain stop valve as a sealed or locked valve. | |||
Section 2.3.1.1 of the DSAR states that two sources of makeup water will be maintainedfor the SFP. The inspector interviewed operations staff personnel and determined thatthe two waters sources were the demineralized water storage tank and fire water. TheDSAR specifies that a minimum of 2,000 gallons shall be maintained in thedemineralized water storage tank. The demineralized water storage tank level indicatordisplays tank level in inches. The 2000 gallon limit amounts to 53.5 inches. On July 13,2007, the tank level was 73.0 inches or 4149 gallons. In addition, the fire water systemwas available for emergency supply of water.Table 5.2 of the DSAR provides the limits for SFP water chemistry and radioactivitylevels. Details of this requirement were documented in site procedure STP 3.6.5,"Monthly Spent Fuel Pool Water Quality Check," Revision 44. The pool water wasroutinely sampled for pH, conductivity and cesium-137 activity. The inspector reviewedthe plant records for March 29, 2006 through June 20, 2007. The licensee had collectedpool water samples on a monthly frequency as required by the DSAR and had analyzedthe samples for the required chemical constituents. Since March 2006, all parametersremained within DSAR limits.The licensee continued tracking the SFP demineralizer differential pressure. TheRadiation Protection Manager stated that if current trends continued it was unlikely thatthe resins would need to be replaced prior to fuel transfer to the independent spent fuelstorage installation (ISFSI). During sorting of irradiated components in the interim storage containers, the licenseestaff located 9 small items that it appear to be fuel pellet fragments. The licensee staffconcluded that these fragments were originally on the energy absorber, and had beenmoved to an interim storage container when the energy absorber was removed from theSFP. The licensee was storing these items in a separate interim storage container. It isexpected that as cleanup of the SFP continues additional small fuel fragments will befound. Upon completion of the SFP cleanup these items and any additional suspectitems found would be evaluated to determine if they were fuel fragments and should bestored with other fuel fragments previously identified. | Section 2.3.1.1 of the DSAR states that two sources of makeup water will be maintainedfor the SFP. The inspector interviewed operations staff personnel and determined thatthe two waters sources were the demineralized water storage tank and fire water. TheDSAR specifies that a minimum of 2,000 gallons shall be maintained in thedemineralized water storage tank. The demineralized water storage tank level indicatordisplays tank level in inches. The 2000 gallon limit amounts to 53.5 inches. On July 13,2007, the tank level was 73.0 inches or 4149 gallons. In addition, the fire water systemwas available for emergency supply of water.Table 5.2 of the DSAR provides the limits for SFP water chemistry and radioactivitylevels. Details of this requirement were documented in site procedure STP 3.6.5,"Monthly Spent Fuel Pool Water Quality Check," Revision 44. The pool water wasroutinely sampled for pH, conductivity and cesium-137 activity. The inspector reviewedthe plant records for March 29, 2006 through June 20, 2007. The licensee had collectedpool water samples on a monthly frequency as required by the DSAR and had analyzedthe samples for the required chemical constituents. Since March 2006, all parametersremained within DSAR limits.The licensee continued tracking the SFP demineralizer differential pressure. TheRadiation Protection Manager stated that if current trends continued it was unlikely thatthe resins would need to be replaced prior to fuel transfer to the independent spent fuelstorage installation (ISFSI). During sorting of irradiated components in the interim storage containers, the licenseestaff located 9 small items that it appear to be fuel pellet fragments. The licensee staffconcluded that these fragments were originally on the energy absorber, and had beenmoved to an interim storage container when the energy absorber was removed from theSFP. The licensee was storing these items in a separate interim storage container. It isexpected that as cleanup of the SFP continues additional small fuel fragments will befound. Upon completion of the SFP cleanup these items and any additional suspectitems found would be evaluated to determine if they were fuel fragments and should bestored with other fuel fragments previously identified. | ||
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to monitor theSSCs subject to the Maintenance Rule as required by 10 CFR 50.65(a)(1). The inspector reviewed the licensee method to assure the timely conduct of STPs. Thelicensee used administrative procedure HBAP C-3#2, "Scheduling of Plant andEquipment Tests" for keeping the STP schedules updated and for issuing the weeklyreminders to the test coordinators. The STP schedule and weekly reminders weremaintained in paper records. The licensee was testing a computer based system toupdate the STP schedule and to generate the weekly reminders.The STP schedule had been maintained. 4.3ConclusionsThe licensee had implemented a maintenance program that met the requirements of theMaintenance Rule provided in 10 CFR 50.65. | to monitor theSSCs subject to the Maintenance Rule as required by 10 CFR 50.65(a)(1). The inspector reviewed the licensee method to assure the timely conduct of STPs. Thelicensee used administrative procedure HBAP C-3#2, "Scheduling of Plant andEquipment Tests" for keeping the STP schedules updated and for issuing the weeklyreminders to the test coordinators. The STP schedule and weekly reminders weremaintained in paper records. The licensee was testing a computer based system toupdate the STP schedule and to generate the weekly reminders.The STP schedule had been maintained. 4.3ConclusionsThe licensee had implemented a maintenance program that met the requirements of theMaintenance Rule provided in 10 CFR 50.65. | ||
5.0Decommissioning Performance and Status Review (IP 71801)5.1 Inspection ScopeThe inspector conducted tours of the site to evaluate whether facility conditions werebeing effectively controlled during SAFSTOR. 5.2Observations and FindingsThe inspector toured the fuel handling building, the Unit 3 control room, and other areasof the facility. Radiological postings were visibl e and met the r equirements of 10 CFR Part 20. Housekeeping and facility conditions were effectively controlled. Most | 5.0Decommissioning Performance and Status Review (IP 71801)5.1 Inspection ScopeThe inspector conducted tours of the site to evaluate whether facility conditions werebeing effectively controlled during SAFSTOR. 5.2Observations and FindingsThe inspector toured the fuel handling building, the Unit 3 control room, and other areasof the facility. Radiological postings were visibl e and met the r equirements of 10 CFR Part 20. Housekeeping and facility conditions were effectively controlled. Most-9-of the areas in the facility were free of radiological contamination and we re accessiblewithout the need of protective clothing. No safety concerns were observed during thetours. The control room indicators associated with monitoring SFP water and liner levelswere confirmed to be functional.5.3Conclusions Radiological conditions of the facility were properly posted. Housekeeping and facilityconditions were effectively controlled. 6.0Occupational Radiation Exposure (IP 83750) | ||
-9-of the areas in the facility were free of radiological contamination and we re accessiblewithout the need of protective clothing. No safety concerns were observed during thetours. The control room indicators associated with monitoring SFP water and liner levelswere confirmed to be functional.5.3Conclusions Radiological conditions of the facility were properly posted. Housekeeping and facilityconditions were effectively controlled. 6.0Occupational Radiation Exposure (IP 83750) | 6.1Inspection ScopeThe inspector reviewed the licensee's recent radiation protection program audit and theirradiological occurrence reporting system. The inspector interviewed the radiationprotection manager and the radiation protection engineer to determine if any of the changes that had been made to the organization, personnel, facilit ies, equipment,programs, or procedures since the last inspection had a negative affect on occupationalradiation protection. The licensee's personnel radiation monitoring program andassociated reports submitted were inspected for compliance with applicable regulatoryrequirements and commitments. 6.2Observations and Findings a.Audits and Appraisals10 CFR 20.1101 required each license to conduct, at least annually, a review of their radiation pr otection program c ontent and implementation. The controlling procedure forconducting this review is Humboldt Bay Administrative Procedure HB-C200,"Requirements for the HBPP Radiation Protection Program." The inspector reviewed EDMS #062500018, the biennial audit of the RadiationProtection, Radioactive Materials Packaging and Transportation, and Radioactive WasteProcessing and Process Control Program. This audit was performed October 9through 20, 2006. The individuals that conducted the audit were independent of theHBPP organization and did not report to any managers at HBPP. This audit identified7 quality problems and made 17 recommendations. The licensee had opened problemreports (SAP Notifications) for all quality problems and recommendations identified in theaudit. The licensee had addressed the quality problems and recommendationsidentified in the audit and had completed all of the actions.To document and evaluate identified radiation protection deficiencies, the licensee hadestablished the Radiological Occurrence Report (ROR) system. This program wasguided by Radiation Control Procedure RCP-2F, "Radiological Occurrence Reports." The ROR system classified occurrences as Level 1 or Level 2. Level 1 is minorradiological occurrences that may be below the threshold for a plant problem report. Level 2 is radiological occurrences that violated procedures, policies and NRC directivesor that require a higher than Level 1 attention. Records maintained by the licensee-10-indicated that 31 RORs were issued in 2006 of which 8 were Level 2. As of July 10, 2007, six RORs had been initiated in calendar year 2007 of which 2 were Level 2. TheLevel 2 RORs were identified as Level 2 because they required a higher attention thanLevel 1, such as assigning dose to an individual. None of the Level 2s were the result ofviolated procedures, policies nor NRC directives. The licensee had effectively followedits process for reporting, documenting, and evaluating radiological occurrences. b.ChangesThere had been no changes in organization, since this area was last reviewed during theMarch 27-31, 2006, inspection. The licensee had added three senior radiationprotection technicians and one decontamination technician as temporary additions tosupport the pool cleanup work and the independent spent fuel storage installationproject.The licensee had acquired three new digital telescoping detector radiation instrumentsfor site use. New operating and testing procedures were been developed and would beimplemented prior to placing these instruments into service. Four radiation control standards and 41 radiation control procedures had been revised,or had been initially issued since this area was last inspected in September 12-14, 2005. The inspector selected two standards and three procedures for review. The reviewsindicated that procedure changes implemented by the licensee provided improvementsor clarifications for the existing procedures. The inspector concluded that theseprocedure changes had a positive effect on the program. c.External and Internal Exposure Control and Other Radiation Protection Inspection AreasThe inspector interviewed the Radiation Protection Engineer and Dosimetry Coordinatorabout the occupational radiation exposure control program, and examined occupationaldosimetry records from January 1, 2006, through June 30, 2007. The records indicatedthat no individual had been classified as a declared pregnant worker and that noplanned special exposures had been conducted. The licensee used thermo luminescent dosimeters (TLDs) provided by the DiabloCanyon Nuclear Power Plant. Diablo Canyon was accredited under the NationalVoluntary Laboratory Accreditation Program for the type of dosimeters used. Thisaccreditation is valid through September 30, 2007. During calender year 2006, the licensee had monitored 143 individuals with TLDs forexternal radiation exposure and 41 individuals with breathing zone air samples forinternal exposures. During calendar year 2006, there were 17 incidents of personnelcontamination and 2 in 2007 as of July 10. Not all personnel contaminations resulted indose being assigned to the individual. When dose assignment was required thelicensee used Varskin Model 2 computer code to evaluate the dose associated with theskin contamination. The cumulative total effective dose equivalent (TEDE) during 2006for all individuals monitored was 4.086 rem; 4.002 rem from external exposure, deepdose equivalent (DDE) and 0.084 rem to internal exposure or committed effective doseequivalent (CEDE). CEDE was calculated based on the results from breathing zone air-11-samples results. The individual with the highest exposure during calendar year 2006received 0.658 rem TEDE, 0.649 rem DDE and 0.009 rem CEDE. The highest CEDEwas 0.030 rem. During calender year 2006, other dose measurements for shallow dose,lens of the eye dose, and extremity dose were all below applicable limits. The licensee identified two cases where the ratio of TLD to electronic dosimeter (ED)readings for an individual radiation worker wearing the two dosimeters during the sameperiod differed by more than 25 percent. A problem report was initiated that was stillopen. Preliminary results of the evaluation found that during the first quarter of 2007when comparing TLD vs ED in about 70 percent of the TLD results were higher than theED. The licensee is continuing to evaluate the reason for this discrepancy, but believesthat it was due to not applying a geometry factor to the ED. All doses assigned werebased on the TLD readings6.3ConclusionsThe audit of the radiation protection program conducted in 2006 met applicablerequirements. The licensee's radiological occurrence report system had properlydocumented and evaluated radiation protection deficiencies. The inspector concludedthat changes made to the number of personnel, equipment, and changes proceduressince the last inspection had a positive effect on occupational radiation protection. Thelicensee was maintaining an effective program to control and monitor occupationalradiation exposures. 7.0Radioactive Waste Treatment and Effluent and Environmental Monitoring (84750) | ||
6.1Inspection ScopeThe inspector reviewed the licensee's recent radiation protection program audit and theirradiological occurrence reporting system. The inspector interviewed the radiationprotection manager and the radiation protection engineer to determine if any of the changes that had been made to the organization, personnel, facilit ies, equipment,programs, or procedures since the last inspection had a negative affect on occupationalradiation protection. The licensee's personnel radiation monitoring program andassociated reports submitted were inspected for compliance with applicable regulatoryrequirements and commitments. 6.2Observations and Findings a.Audits and Appraisals10 CFR 20.1101 required each license to conduct, at least annually, a review of their radiation pr otection program c ontent and implementation. The controlling procedure forconducting this review is Humboldt Bay Administrative Procedure HB-C200,"Requirements for the HBPP Radiation Protection Program." The inspector reviewed EDMS #062500018, the biennial audit of the RadiationProtection, Radioactive Materials Packaging and Transportation, and Radioactive WasteProcessing and Process Control Program. This audit was performed October 9through 20, 2006. The individuals that conducted the audit were independent of theHBPP organization and did not report to any managers at HBPP. This audit identified7 quality problems and made 17 recommendations. The licensee had opened problemreports (SAP Notifications) for all quality problems and recommendations identified in theaudit. The licensee had addressed the quality problems and recommendationsidentified in the audit and had completed all of the actions.To document and evaluate identified radiation protection deficiencies, the licensee hadestablished the Radiological Occurrence Report (ROR) system. This program wasguided by Radiation Control Procedure RCP-2F, "Radiological Occurrence Reports." The ROR system classified occurrences as Level 1 or Level 2. Level 1 is minorradiological occurrences that may be below the threshold for a plant problem report. Level 2 is radiological occurrences that violated procedures, policies and NRC directivesor that require a higher than Level 1 attention. Records maintained by the licensee | 7.1Inspection ScopeThe inspector interviewed cognizant personnel and reviewed selected documents todetermine if any significant changes had been made by the licensee that affected (1) thelicensee's liquid and airborne radwaste, water chemistry, and radiological environmentalmonitoring organization or (2) the offsite dose calculation manual (ODCM). Theinspector reviewed the status of radioactive waste process and effluent monitors. The2006 Annual Radiological Environmental Monitoring and the 2006 Annual RadioactiveEffluent Release Reports were reviewed. 7.2 Observations and Findings a.Audits and AppraisalsAs noted in Section 6.1a above, the inspector reviewed EDMS #062500018, the biennialaudit of the Radiation Protection, Radioactive Materials Packaging and Transportation,and Radioactive Waste Processing and Process Control Program. This audit wasperformed October 9 through 20, 2006. The individuals that conducted the audit wereindependent of the HBPP organization and did not report to any managers at HBPP. This audit identified 7 quality problems and made 17 recommendations. The licenseehad opened problem reports (SAP Notifications) for all quality problems andrecommendations identified in the audit. The licensee had addressed the quality-12-problems and recommendations identified in the audit and had completed all of theactions. b.ChangesThis area was last inspected March 27-31, 2006. There had been no significantchanges made to the site radiological monitoring organization. The licensee lastupdated the ODCM to Revision 13, on March 2, 2007. This change has not yet beenformally reported to the NRC. It will be reported with issuance of the Annual RadioactiveEffluent Release Report for 2007. This change to the ODCM was required to addresschanges to the radwaste system. A new Radioactive Liquid Effluent Monitoring Systemwas declared operation on March 19, 2007. New components incl uded scintillationdetector, analyzer, activity monitor, system indications including alarms, high alarm tripfeature, and power supply. The only components not changed in the Radioactive WasteLiquid Effluent Monitoring System were the radioactive check source, liquid sampler andthe associated piping. b.Process and Effluent MonitorsSection 2.1 of the ODCM specified that the radioactive liquid effluent monitoringinstrumentation shall have at least one channel of gross radioactivity monitoringproviding the capability to automatically terminate the effluent release based on grossactivity at all times. The surveillances for this instrument included daily channel check,quarterly source check and functional test, and annual channel calibration. As notedabove a new Radioactive Liquid Effluent Monitoring System was declared operationalon March 19, 2007. The inspector reviewed selected records of surveillances performedon this instrument and concluded that the instrument was being maintained as requiredby the ODCM. The instrument was last calibrated on March 2, 2007, and wasoperational at the time of the site visit. During the revision of the ODCM, the licensee staff identified an error on the formulaused for setting the Radioactive Liquid Effluent Monitor (RLEM) alarm. A problemreport, SAPN 1242451, was opened to evaluate this problem. The evaluation concludedthat this error could have resulted in liquid releases exceeding the 10 CFR Part 20Appendix B limit only if an inadvertent discharge with no circulating water pumpsoperating occurred. The licensee reviewed their records and determined that noinadvertent discharges had occurred and all discharges had at least one circulatingpump operational. c.Annual Radiological Environmental Monitoring Report for 2006Technical Specification 5.7.2 required that an Annual Radiological EnvironmentalMonitoring Report be submitted to the NRC prior to May 1 covering the previouscalendar year. On April 30, 2007, the licensee submitted the 2006 report. This reportindicated that direct radiation, surface water, and groundwater and were being monitoredas required. Airborne, ingestion and terrestrial pathway monitoring was not required bythe ODCM. The environmental report submitted as part of the SAFSTOR licenserequest established baseline conditions for those pathways. The licensee monitorsdirect radiation at 16 locations onsite. The onsite locations were slightly higher this year-13-than in previous years. The licensee attributed the slight increase to the movement andstorage of radioactive resin onsite. Radioactivity levels in other sampled media wereconsistent with previous years and all results were below the NRC required reportablelevels. a.Annual Radioactive Effluent Release Report for 2006Technical Specification 5.7.3 required that an Annual Radioactive Effluent ReleaseReport be submitted prior to April 1 of each year. In accordance with 10 CFR 50.36(a),the report must cover the activities of the previous calender year. On March 28, 2007,the licensee submitted the 2006 Annual Radioactive Effluent Release Report on a timelybasis. The report included summaries of radioactive gaseous and liquid releases fromthe site. The report concluded that the releases of radioactivity in gaseous and liquideffluents were well below the 10 CFR 50 Appendix I numerical as low as reasonablyachievable (ALARA) guidelines and that the maximum potential direct radiation dosealthough slightly increase over previous years remained well below the limits of10 CFR 20.1302(b)(2(ii).There were no abnormal gaseous or liquid releases during 2005. There were eightliquid batch releases during 2006 and no continuous liquid releases. There were nobatch gaseous releases during 2006. In 2006, no solid radioactive waste was disposed. | ||
-10-indicated that 31 RORs were issued in 2006 of which 8 were Level 2. As of July 10, 2007, six RORs had been initiated in calendar year 2007 of which 2 were Level 2. TheLevel 2 RORs were identified as Level 2 because they required a higher attention thanLevel 1, such as assigning dose to an individual. None of the Level 2s were the result ofviolated procedures, policies nor NRC directives. The licensee had effectively followedits process for reporting, documenting, and evaluating radiological occurrences. b.ChangesThere had been no changes in organization, since this area was last reviewed during theMarch 27-31, 2006, inspection. The licensee had added three senior radiationprotection technicians and one decontamination technician as temporary additions tosupport the pool cleanup work and the independent spent fuel storage installationproject.The licensee had acquired three new digital telescoping detector radiation instrumentsfor site use. New operating and testing procedures were been developed and would beimplemented prior to placing these instruments into service. Four radiation control standards and 41 radiation control procedures had been revised,or had been initially issued since this area was last inspected in September 12-14, 2005. The inspector selected two standards and three procedures for review. The reviewsindicated that procedure changes implemented by the licensee provided improvementsor clarifications for the existing procedures. The inspector concluded that theseprocedure changes had a positive effect on the program. c.External and Internal Exposure Control and Other Radiation Protection Inspection AreasThe inspector interviewed the Radiation Protection Engineer and Dosimetry Coordinatorabout the occupational radiation exposure control program, and examined occupationaldosimetry records from January 1, 2006, through June 30, 2007. The records indicatedthat no individual had been classified as a declared pregnant worker and that noplanned special exposures had been conducted. The licensee used thermo luminescent dosimeters (TLDs) provided by the DiabloCanyon Nuclear Power Plant. Diablo Canyon was accredited under the NationalVoluntary Laboratory Accreditation Program for the type of dosimeters used. Thisaccreditation is valid through September 30, 2007. During calender year 2006, the licensee had monitored 143 individuals with TLDs forexternal radiation exposure and 41 individuals with breathing zone air samples forinternal exposures. During calendar year 2006, there were 17 incidents of personnelcontamination and 2 in 2007 as of July 10. Not all personnel contaminations resulted indose being assigned to the individual. When dose assignment was required thelicensee used Varskin Model 2 computer code to evaluate the dose associated with theskin contamination. The cumulative total effective dose equivalent (TEDE) during 2006for all individuals monitored was 4.086 rem; 4.002 rem from external exposure, deepdose equivalent (DDE) and 0.084 rem to internal exposure or committed effective doseequivalent (CEDE). CEDE was calculated based on the results from breathing zone air | |||
-11-samples results. The individual with the highest exposure during calendar year 2006received 0.658 rem TEDE, 0.649 rem DDE and 0.009 rem CEDE. The highest CEDEwas 0.030 rem. During calender year 2006, other dose measurements for shallow dose,lens of the eye dose, and extremity dose were all below applicable limits. The licensee identified two cases where the ratio of TLD to electronic dosimeter (ED)readings for an individual radiation worker wearing the two dosimeters during the sameperiod differed by more than 25 percent. A problem report was initiated that was stillopen. Preliminary results of the evaluation found that during the first quarter of 2007when comparing TLD vs ED in about 70 percent of the TLD results were higher than theED. The licensee is continuing to evaluate the reason for this discrepancy, but believesthat it was due to not applying a geometry factor to the ED. All doses assigned werebased on the TLD readings6.3ConclusionsThe audit of the radiation protection program conducted in 2006 met applicablerequirements. The licensee's radiological occurrence report system had properlydocumented and evaluated radiation protection deficiencies. The inspector concludedthat changes made to the number of personnel, equipment, and changes proceduressince the last inspection had a positive effect on occupational radiation protection. Thelicensee was maintaining an effective program to control and monitor occupationalradiation exposures. 7.0Radioactive Waste Treatment and Effluent and Environmental Monitoring (84750) | |||
7.1Inspection ScopeThe inspector interviewed cognizant personnel and reviewed selected documents todetermine if any significant changes had been made by the licensee that affected (1) thelicensee's liquid and airborne radwaste, water chemistry, and radiological environmentalmonitoring organization or (2) the offsite dose calculation manual (ODCM). Theinspector reviewed the status of radioactive waste process and effluent monitors. The2006 Annual Radiological Environmental Monitoring and the 2006 Annual RadioactiveEffluent Release Reports were reviewed. 7.2 Observations and Findings a.Audits and AppraisalsAs noted in Section 6.1a above, the inspector reviewed EDMS #062500018, the biennialaudit of the Radiation Protection, Radioactive Materials Packaging and Transportation,and Radioactive Waste Processing and Process Control Program. This audit wasperformed October 9 through 20, 2006. The individuals that conducted the audit wereindependent of the HBPP organization and did not report to any managers at HBPP. This audit identified 7 quality problems and made 17 recommendations. The licenseehad opened problem reports (SAP Notifications) for all quality problems andrecommendations identified in the audit. The licensee had addressed the quality | |||
-12-problems and recommendations identified in the audit and had completed all of theactions. b.ChangesThis area was last inspected March 27-31, 2006. There had been no significantchanges made to the site radiological monitoring organization. The licensee lastupdated the ODCM to Revision 13, on March 2, 2007. This change has not yet beenformally reported to the NRC. It will be reported with issuance of the Annual RadioactiveEffluent Release Report for 2007. This change to the ODCM was required to addresschanges to the radwaste system. A new Radioactive Liquid Effluent Monitoring Systemwas declared operation on March 19, 2007. New components incl uded scintillationdetector, analyzer, activity monitor, system indications including alarms, high alarm tripfeature, and power supply. The only components not changed in the Radioactive WasteLiquid Effluent Monitoring System were the radioactive check source, liquid sampler andthe associated piping. b.Process and Effluent MonitorsSection 2.1 of the ODCM specified that the radioactive liquid effluent monitoringinstrumentation shall have at least one channel of gross radioactivity monitoringproviding the capability to automatically terminate the effluent release based on grossactivity at all times. The surveillances for this instrument included daily channel check,quarterly source check and functional test, and annual channel calibration. As notedabove a new Radioactive Liquid Effluent Monitoring System was declared operationalon March 19, 2007. The inspector reviewed selected records of surveillances performedon this instrument and concluded that the instrument was being maintained as requiredby the ODCM. The instrument was last calibrated on March 2, 2007, and wasoperational at the time of the site visit. During the revision of the ODCM, the licensee staff identified an error on the formulaused for setting the Radioactive Liquid Effluent Monitor (RLEM) alarm. A problemreport, SAPN 1242451, was opened to evaluate this problem. The evaluation concludedthat this error could have resulted in liquid releases exceeding the 10 CFR Part 20Appendix B limit only if an inadvertent discharge with no circulating water pumpsoperating occurred. The licensee reviewed their records and determined that noinadvertent discharges had occurred and all discharges had at least one circulatingpump operational. c.Annual Radiological Environmental Monitoring Report for 2006Technical Specification 5.7.2 required that an Annual Radiological EnvironmentalMonitoring Report be submitted to the NRC prior to May 1 covering the previouscalendar year. On April 30, 2007, the licensee submitted the 2006 report. This reportindicated that direct radiation, surface water, and groundwater and were being monitoredas required. Airborne, ingestion and terrestrial pathway monitoring was not required bythe ODCM. The environmental report submitted as part of the SAFSTOR licenserequest established baseline conditions for those pathways. The licensee monitorsdirect radiation at 16 locations onsite. The onsite locations were slightly higher this year | |||
-13-than in previous years. The licensee attributed the slight increase to the movement andstorage of radioactive resin onsite. Radioactivity levels in other sampled media wereconsistent with previous years and all results were below the NRC required reportablelevels. a.Annual Radioactive Effluent Release Report for 2006Technical Specification 5.7.3 required that an Annual Radioactive Effluent ReleaseReport be submitted prior to April 1 of each year. In accordance with 10 CFR 50.36(a),the report must cover the activities of the previous calender year. On March 28, 2007,the licensee submitted the 2006 Annual Radioactive Effluent Release Report on a timelybasis. The report included summaries of radioactive gaseous and liquid releases fromthe site. The report concluded that the releases of radioactivity in gaseous and liquideffluents were well below the 10 CFR 50 Appendix I numerical as low as reasonablyachievable (ALARA) guidelines and that the maximum potential direct radiation dosealthough slightly increase over previous years remained well below the limits of10 CFR 20.1302(b)(2(ii).There were no abnormal gaseous or liquid releases during 2005. There were eightliquid batch releases during 2006 and no continuous liquid releases. There were nobatch gaseous releases during 2006. In 2006, no solid radioactive waste was disposed. | |||
The ODCM was not revised during this 2006. 7.3ConclusionsThe audit of the radiation protection program, which included the effluent andenvironmental monitoring conducted in 2006 met applicable requirements. The offsite dose calculation manual was revised in March 2007. A new RadioactiveLiquid Effluent Monitoring System was installed and declared operational March 2007. The radioactive waste process and liquid effluent monitors were operational, properlycalibrated and were being maintained as specified in the offsite dose calculation manual.The Annual Radiological Environmental Monitoring and the Annual Radioactive EffluentRelease Report for calender year 2006 were submitted on a timely basis and metapplicable requirements. Radioactivity levels in the sampled media were generallyconsistent with previous years and were below the NRC required reportable levels. Thereleases of radioactivity in gaseous and liquid effluents in 2006 did not exceedapplicable regulatory limits.8.0Exit MeetingOn July 13, 2007, at the conclusion of the site visit, the inspector presented to the plantmanager and other licensee staff members the preliminary results of the inspection. Thelicensee did not identify as proprietary any information provided to, or reviewed by, theinspector. | The ODCM was not revised during this 2006. 7.3ConclusionsThe audit of the radiation protection program, which included the effluent andenvironmental monitoring conducted in 2006 met applicable requirements. The offsite dose calculation manual was revised in March 2007. A new RadioactiveLiquid Effluent Monitoring System was installed and declared operational March 2007. The radioactive waste process and liquid effluent monitors were operational, properlycalibrated and were being maintained as specified in the offsite dose calculation manual.The Annual Radiological Environmental Monitoring and the Annual Radioactive EffluentRelease Report for calender year 2006 were submitted on a timely basis and metapplicable requirements. Radioactivity levels in the sampled media were generallyconsistent with previous years and were below the NRC required reportable levels. Thereleases of radioactivity in gaseous and liquid effluents in 2006 did not exceedapplicable regulatory limits.8.0Exit MeetingOn July 13, 2007, at the conclusion of the site visit, the inspector presented to the plantmanager and other licensee staff members the preliminary results of the inspection. Thelicensee did not identify as proprietary any information provided to, or reviewed by, theinspector. | ||
ATTACHMENT 1SUPPLEMENTAL INSPECTION INFORMATIONPARTIAL LIST OF PERSONS CONTACTEDLicensee Personnel: | ATTACHMENT 1SUPPLEMENTAL INSPECTION INFORMATIONPARTIAL LIST OF PERSONS CONTACTEDLicensee Personnel: | ||
J. Albers, Radiation Protection ManagerC. Caldwell, Unit 3 SupervisorJ. Chadwick, Senior Radiation Protection EngineerJ. Davis, Radiation Protection EngineerZ. Easley, Security SupervisorG. Bierbaum, Design EngineerV. Jensen, Quality Control SupervisorG. Mason, Quality Assurance SupervisorL. Sharp, Director and Plant Manager - NuclearL. Pulley, ISFSI ManagerM. Smith, Engineering ManagerD. Sokolsky, Licensing SupervisorR. Sorensen, Programs CoordinatorR. Willis, Plant Manager FossilINSPECTION PROCEDURES USEDIP 36801 Organization, Management, and Cost ControlsIP 37801 Safety Reviews, Design Changes, and ModificationsIP 60801 Spent Fuel Pool SafetyIP 62801 Maintenance and SurveillancesIP 71801 Decommissioning Performance and Status ReviewIP 83750 Occupational Radiation ExposureIP 84750 Radioactive Waste Treatment, Effluent and Environmental Monitoring ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed None Discussed None | J. Albers, Radiation Protection ManagerC. Caldwell, Unit 3 SupervisorJ. Chadwick, Senior Radiation Protection EngineerJ. Davis, Radiation Protection EngineerZ. Easley, Security SupervisorG. Bierbaum, Design EngineerV. Jensen, Quality Control SupervisorG. Mason, Quality Assurance SupervisorL. Sharp, Director and Plant Manager - NuclearL. Pulley, ISFSI ManagerM. Smith, Engineering ManagerD. Sokolsky, Licensing SupervisorR. Sorensen, Programs CoordinatorR. Willis, Plant Manager FossilINSPECTION PROCEDURES USEDIP 36801 Organization, Management, and Cost ControlsIP 37801 Safety Reviews, Design Changes, and ModificationsIP 60801 Spent Fuel Pool SafetyIP 62801 Maintenance and SurveillancesIP 71801 Decommissioning Performance and Status ReviewIP 83750 Occupational Radiation ExposureIP 84750 Radioactive Waste Treatment, Effluent and Environmental Monitoring ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed None Discussed None-2-LIST OF ACRONYMSALARAAs Low As Reasonably Achievable CAPR Corrective Actions to Prevent Recurrence CEDE Committed Effective Dose EquivalentCFHCertified Fuel HandlerDDE Deep Dose EquivalentDSAR Defueled Safety Analysis ReportED Electronic DosimeterHBAP Humboldt Bay Administrative ProcedureIPInspection ProcedureLBIE Licensing Basis Impact EvaluationNCRs Non-Conformance ReportsNSOC Nuclear Safety Oversight Committee ODCM Offsite Dose Calculation Manual PSRC Plant Staff Review CommitteeRLEM Radioactive Liquid Effluent MonitorROR Radiological Occurrence ReportSAPNSAP Notification (Problem Report)SFPSpent Fuel PoolSSCs Structure, System or ComponentsSTPs Surveillance Test ProceduresTEDE Total Effective Dose Equivalent TLDs Thermo Luminescent Dosimeters ATTACHMENT 2PARTIAL LIST OF DOCUMENTS REVIEWEDAudits and Appraisals*EDMS # 062500018, HBPP Radiation Protection, Radioactive Materials Packaging andTransportation, and Radioactive Waste Processing and Process Control Program Auditreport, performed October 10 through 20, 2006, report approved November 10, 2006.Corrective Action Program Documents (SAPN & Nonconformance Reports)*Corrective Action Program Report SAPN 1242451, Discrepancy between the ODCMcalculations used for setting the Radioactive Liquid Effluent Monitor (RLEM) alarm andthe basis for the calculations.Procedures*Humboldt Bay Administrative Procedure (HBAP) A-1, HBPP Organization and StaffQualifications," Appendix 6.4, Revision 25, effective September 7, 2006.*Humboldt Bay Administrative Procedure HBAP C-3 #2, "Scheduling of Plant andEquipment Tests," Revision 21B, effective April 5, 2007.*Humboldt Bay Administrative Procedure HBAP C-19, "Licensing Basis Impact Evaluation(LBIE)," Revision 21, effective March 31, 2006.*Humboldt Bay Administrative Procedure, HBAP C-40, "Maintenance Program," Revision 18, effective July 12, 2007.*Humboldt Bay Administrative Procedure, HBAP C-40 #1, "Maintenance RuleCompliance," Revision 4, effective January 11, 2007.*Humboldt Bay Radiat ion Control Standard HBRCS-2, "Controlling Total Effective DoseEquivalent As Low As Reasonably Achievable," Revision 8, effective March 23, 2007.*Humboldt Bay Radiation Control Standard RCS-12, "Respiratory Protection Program,"Revision 3, effective March 23, 2007.*Humboldt Bay Radiation Control Procedure RCP-2D, "Evaluation of Internal Depositionof Radioactive Material," Revision 30, effective December 1, 2005.*Humboldt Bay Radiation Control Procedure RCP-2F, "Radiological Occurrence Reports,"Revision 7, effective September 16, 2002.*Humboldt Bay Radiation Control Procedure RCP-4I, "Occupational Exposure Reporting(NRC Form 5)," Revision 2A, effective May 11, 2006. | ||
-2-LIST OF ACRONYMSALARAAs Low As Reasonably Achievable CAPR Corrective Actions to Prevent Recurrence CEDE Committed Effective Dose EquivalentCFHCertified Fuel HandlerDDE Deep Dose EquivalentDSAR Defueled Safety Analysis ReportED Electronic DosimeterHBAP Humboldt Bay Administrative ProcedureIPInspection ProcedureLBIE Licensing Basis Impact EvaluationNCRs Non-Conformance ReportsNSOC Nuclear Safety Oversight Committee ODCM Offsite Dose Calculation Manual PSRC Plant Staff Review CommitteeRLEM Radioactive Liquid Effluent MonitorROR Radiological Occurrence ReportSAPNSAP Notification (Problem Report)SFPSpent Fuel PoolSSCs Structure, System or ComponentsSTPs Surveillance Test ProceduresTEDE Total Effective Dose Equivalent TLDs Thermo Luminescent Dosimeters ATTACHMENT 2PARTIAL LIST OF DOCUMENTS REVIEWEDAudits and Appraisals*EDMS # 062500018, HBPP Radiation Protection, Radioactive Materials Packaging andTransportation, and Radioactive Waste Processing and Process Control Program Auditreport, performed October 10 through 20, 2006, report approved November 10, 2006.Corrective Action Program Documents (SAPN & Nonconformance Reports)*Corrective Action Program Report SAPN 1242451, Discrepancy between the ODCMcalculations used for setting the Radioactive Liquid Effluent Monitor (RLEM) alarm andthe basis for the calculations.Procedures*Humboldt Bay Administrative Procedure (HBAP) A-1, HBPP Organization and StaffQualifications," Appendix 6.4, Revision 25, effective September 7, 2006.*Humboldt Bay Administrative Procedure HBAP C-3 #2, "Scheduling of Plant andEquipment Tests," Revision 21B, effective April 5, 2007.*Humboldt Bay Administrative Procedure HBAP C-19, "Licensing Basis Impact Evaluation(LBIE)," Revision 21, effective March 31, 2006.*Humboldt Bay Administrative Procedure, HBAP C-40, "Maintenance Program," Revision 18, effective July 12, 2007.*Humboldt Bay Administrative Procedure, HBAP C-40 #1, "Maintenance RuleCompliance," Revision 4, effective January 11, 2007.*Humboldt Bay Radiat ion Control Standard HBRCS-2, "Controlling Total Effective DoseEquivalent As Low As Reasonably Achievable," Revision 8, effective March 23, 2007.*Humboldt Bay Radiation Control Standard RCS-12, "Respiratory Protection Program,"Revision 3, effective March 23, 2007.*Humboldt Bay Radiation Control Procedure RCP-2D, "Evaluation of Internal Depositionof Radioactive Material," Revision 30, effective December 1, 2005.*Humboldt Bay Radiation Control Procedure RCP-2F, "Radiological Occurrence Reports,"Revision 7, effective September 16, 2002.*Humboldt Bay Radiation Control Procedure RCP-4I, "Occupational Exposure Reporting(NRC Form 5)," Revision 2A, effective May 11, 2006. | |||
-2- Data Sheets*List of Certified fuel Handlers as of July 12, 2007.*Attachment 10.1, Surveillance Test Procedure 3.21.4, Radioactive Liquid EffluentMonitor Source Check, Calibration, and Channel Functional Test, Revision 43,performed March 2, 2007.*Attachment 8.1, Surveillance Test Procedure 3.21.3, Weekly Radioactive Liquid EffluentMonitor Checks, Revision 46, performed March 2, March 6, March 8, March 13,March 19, March 20, March 22, and March 27, 2007.Reports*Annual Radioactive Effluent Release Report for 2006, HBL-07-004, March 28, 2007. | -2- Data Sheets*List of Certified fuel Handlers as of July 12, 2007.*Attachment 10.1, Surveillance Test Procedure 3.21.4, Radioactive Liquid EffluentMonitor Source Check, Calibration, and Channel Functional Test, Revision 43,performed March 2, 2007.*Attachment 8.1, Surveillance Test Procedure 3.21.3, Weekly Radioactive Liquid EffluentMonitor Checks, Revision 46, performed March 2, March 6, March 8, March 13,March 19, March 20, March 22, and March 27, 2007.Reports*Annual Radioactive Effluent Release Report for 2006, HBL-07-004, March 28, 2007. | ||
Revision as of 22:14, 12 July 2019
| ML072150205 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 08/03/2007 |
| From: | Spitzberg D NRC/RGN-IV/DNMS/FCDB |
| To: | Keenan J Pacific Gas & Electric Co |
| References | |
| IR-07-003 | |
| Download: ML072150205 (21) | |
Text
August 3, 2007Mr. John Senior Vice President - Generation and Chief Nuclear Officer Pacific Gas and Electric Company P.O. Box 770000, Mail Code B32San Francisco, California 94177-0001 SUBJECT:NRC INSPECTION REPORT 050-00133/07-003
Dear Mr. Keenan:
An NRC inspection was conducted on July 10 -13, 2007, at your Humboldt Bay Power PlantUnit 3 facility. This inspection was an examination of activities conducted under your license asthey relate to safety and compliance of the Commission's rules and regulations and with theconditions of your license. Within these areas, the inspection included reviews of yourorganization and management controls, safety reviews, design changes and modifications,spent fuel pool safety, maintenance and surveillance, deco mmissioning performance,occupational radiation exposure, and radioactive waste treatment, effluent and environmentalmonitoring. On July 13, 2007, at the conclusion of the site visit, an exit briefing was conductedwith Mr. Loren Sharp, Director and Plant Manager, and other members of your staff. Theenclosed report presents the scope and results of that inspection. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response (if any) will be made available electronically for pub lic inspectionin the NRC Public Document Room or from the NRC's document system (ADAMS), accessiblefrom the NRC Web site at http://www.nrc.gov/reading-rm/Adams.html. To the extent possible,your response, if any, should not include any personal privacy, proprietary, or safeguardsinformation so that it can be made available to the public without redaction. Should you have any questions concerning this inspection, please contact the undersigned at(817) 860-8191 or Emilio M.
Garcia at (530) 756-3910.
Sincerely,
/RA/D. Blair Spitzberg, Ph.D., ChiefFuel Cycle and Decommissioning BranchDocket No.: 050-00133License No.: DPR-7
Enclosure:
NRC Inspection Report 050-00133/07-003 Pacific Gas and Electric Company - 2 -
REGION IV Docket No.:050-00133License No.:DPR-7 Report No.:050-00133/07-003 Licensee:Pacific Gas and Electric Company (PG&E)
Facility:Humboldt Bay Power Plant (HBPP), Unit 3Location:1000 King Salmon AvenueEureka, California 95503Dates:July 10 - 13, 2007 Inspector:Emilio M. Garcia, Health PhysicistFuel Cycle and Decommissioning Branch, Region IVAccompanied by:John B. Hickman, Project ManagerReactor Decommissioning Branch, Office of Federal and StateMaterials and Environmental Management ProgramsThomas H. Youngblood, Jr., Health PhysicistReactor Decommissioning Branch, Office of Federal and StateMaterials and Environmental Management ProgramsApproved By:D. Blair Spitzberg, Ph.D., ChiefFuel Cycle and Decommissioning Branch, Region IVAttachments:Supplemental Inspection Information ADAMS Entry:IR 05000133-07-03, on 07/09-13/07; Pacific Gas & Electric Co.;Humboldt Bay, Unit 3. No Violations.
-2-EXECUTIVE SUMMARYHumboldt Bay Power Plant, Unit 3NRC Inspection Report 050-00133/07-003The Humboldt Bay Power Plant (HBPP), Unit 3 was shutdown in 1976. The facility has been ina SAFSTOR status since shutdown with minimal decommissioning activity. This routineinspection was conducted to review the licensee's organization and management controls,safety reviews, design changes and modifications, spent fuel pool safety, maintenance andsurveillance, decommissioning performance, occupational radiation exposures, and radioactivewaste treatment, effluent and environmental monitoring.Organization, Management and Cost Controls*The licensee had sufficient staff to conduct the work in progress, including an amplenumber of certified fuel handlers. The onsite review committee was functioning inaccordance with quality assurance program requirements. The composition,organization and charter of the offsite review committee were under review at the time ofthe inspection. The offsite review committee had yet to meet in 2007 (Section 1).Safety Reviews, Design Changes, and Modification*The licensee's safety review program was conducted in compliance with 10 CFR 50.59requirements. The licensee had established and implemented a non-conformanceprogram that was in compliance with Quality Assurance Plan requirements (Section 2).Spent Fuel Pool Safety*The licensee was maintaining the SFP water level and water chemistry in accordancewith Technical Specifications requirements and Defueled Safety Analysis Reportcommitments (Section 3).Maintenance and Surveillance*The licensee had implemented a maintenance program which met the requirements ofthe Maintenance Rule provided in 10 CFR 50.65 (Section 4). Decommissioning Performance and Status Review*Radiological conditions of the facility were properly posted. Housekeeping and facilityconditions were effectively controlled (Section 5).
-3-Occupational Radiation Exposure*The audit of the radiation protection program conducted in 2006 met applicablerequirements. The licensee's radiological occurrence report system had properlydocumented and evaluated radiation protection deficiencies. The inspector concludedthat changes made to the number of personnel, equipment, and procedures since thelast inspection had a positive effect on occupational radiation protection. The licenseewas maintaining an effective program to control and monitor occupational radiationexposures (Section 6).Radioactive Waste Treatment, Effluent and Environmental Monitoring*The audit of the radiation protection program, which included the effluent andenvironmental monitoring conducted in 2006 met applicable requirements. The offsite dose calculation manual was revised in March 2007. A new RadioactiveLiquid Effluent Monitoring System was installed and declared operational in March 2007(Section 7). *The radioactive waste process and liquid effluent monitors were operational, properlycalibrated and were being maintained as specified in the offsite dose calculation manual(Section 7).*The Annual Radiological Environmental Monitoring and the Annual Radioactive EffluentRelease Report for calender year 2006 were submitted on a timely basis and metapplicable requirements. Radioactivity levels in the sampled media were generallyconsistent with previous years and were below the NRC required reportable levels. Thereleases of radioactivity in gaseous and liquid effluents in 2006 did not exceedapplicable regulatory limits (Section 7).
-4-Report DetailsSummary of Plant StatusHumboldt Bay Power Plant, Unit 3, is currently in decommissioning SAFSTOR status. Unit 3received an operating license from the Atomic Energy Commission on August 28, 1962. OnJuly 2, 1976, Unit 3 was shutdown for annual refueling and seismic modifications. This workwas suspended in December 1980, and in June 1983, PG&E announced its intention todecommission the unit. Unit 3 has been essentially in SAFSTOR since July 1985. On July 19,1988, NRC approved the licensee's SAFSTOR plan and amended the license to a possess-but-not-operate status. The license will expire on November 9, 2015. The facility hasundergone minimal decommissioning activities since shutdown. 1.0Organization, Management, and Cost Controls (36801)
1.1Inspection ScopeThe inspector reviewed site staffing and the onsite and offsite safety review committeesfor compliance with regulatory requirements, site procedures, and licenseecommitments.1.2Observations and Findings a.Site OrganizationTechnical Specifications 5.2.1 provides the requirements for the onsite and offsiteorganizations necessary for the safe storage of irradiated fuel. The onsite nuclearorganization chart was provided in site procedure Humboldt Bay AdministrativeProcedure (HBAP) A-1, HBPP Organization and Staff Qualifications," Appendix 6.4,Revision 25. This procedure had not been revised since the last inspection in March2007. The inspector compared the actual structure in place at the time of the inspection to the procedure r equirements. All staff positions had been filled, except two. Thepositions of Decommissioning Project Manager and the Unit 3 Operations Managerremained opened as of the time of the inspection. The position of Unit 3 Supervisor hadbeen filled by the individual who previously served as an interim appointment.The position of Dire ctor and Plant Manager had been filled on June 1, 2007, with a newindividual. The licensee had verified and documented that the individual met orexceeded the minimum qualifications of ANSI N18.1 - 1971 for the position of NuclearPlant Manager.Section 5.2.2 of Technical Specifications states that at least one certified fuel handler(CFH) shall be onsite when fuel is in the spent fuel pool (SFP). As of July 12, 2007,there were 17 CFHs employed by the licensee. The licensee stated that this staffinglevel permitted meeting the Technical Specification requirements.
-5- b.Onsite and Offfsite Review CommitteesThe Quality Assurance Plan, Revision 20, provides the requirements for the Plant StaffReview Committee (PSRC) and the Nuclear Safety Oversight Committee (NSOC). Theinspector reviewed the implementation of the committees to ensure compliance withquality assurance program requirements. The PSRC was the onsite group that reviewed proposed changes, tests andexperiments, plant modifications, procedure revisions, and other issues having nuclearsafety significance. As of July 11, 2007, the PSRC had met 19 times during 2007. Theinspector reviewed the PSRC meeting minutes from March to June 2007. Minutesdocumented that the quorum requirements had been met and provided a list of allsubjects reviewed. The committee reviewed and approved, as appropriate, proposedprocedure changes, temporary procedures, plant modifications, negative trends, andnonconformances. Reasons were documented when proposed changes or procedureswere rejected by the committee.The NSOC provided high level review and oversight of site activities including the PSRC. The NSOC was required to meet at least twice per year. The only site person that was amember of this committee was the plant manager. The committee had not yet met in2007. The Licensing Supervisor stated that the composition, organization and charter ofthe NSOC were under review at the time of the inspection. Although no meeting wasscheduled, the Licensing Supervisor expected that the first meeting of the year wouldoccur in September.1.3ConclusionsThe licensee had sufficient staff to conduct the work in progress, including an amplenumber of certified fuel handlers. The onsite review committee was functioning inaccordance with quality assurance program requirements. The composition,organization and charter of the offsite review committee were under review at the time ofthe inspection. The offsite review committee had yet to meet in 2007.2.0Safety Reviews, Design Changes, and Modifications (37801)
2.1Inspection ScopeThe inspector conducted reviews of the licensee's design change and nonconformanceprograms to ensure compliance with the requirements of 10 CFR 50.59 and QualityAssurance Plan requirements. 2.2Observations and Findings a.Design Change ProcessLicensee procedure HBAP C-19, "Licensing Basis Impact Evaluation (LBIE),"Revision 21, establishes the requirements for evaluating potential effects on licensingbasis documents from proposed changes to the facility, procedures, te st or ex periments. This procedure was used to determine if 10 CFR 50.59 evaluations were required and-6-whether prior NRC approval was required before implementing the changes. Theinspector reviewed selected design change packages to ascertain whether the changesincluded a safety review or safety screening and adequate explanation of the changebeing proposed. The inspector reviewed five design change notices issued since thisarea was last inspected in March 2007. Each package included a safety screen thatincluded consideration of the requirements of 10 CFR 50.59. Other attributesconsidered included impacts on decommissioning and whether changes were requiredto be implemented in licensing basis documents, site procedures, and site drawings. Allsafety screens were complete. None of the changes involved a full safety evaluation. Further, the design change notices provided sufficient detail to explain what was being changed. b.Nonconformance ReportsSection 3.1.4 of the Quality Assurance Plan states that measures shall be establishedfor documenting, reviewing, and dispositioning of quality problems and non-conformances. During 2006, four non-conformance reports (NCRs) were opened. TheNCRs were discussed in inspection report 05000133/2006003. No additional NCRs hadbeen opened. At the time of this inspection, two of the 2006 NCRs remained openpending completion of corrective actions to prevent recurrence (CAPR). NCR 06-04 had been initiated by the previous Plant Manager to evaluate and resolve anapparent weakness in the standard test procedure scheduling process. This NCR wasprovided for closure evaluation to on June 2007 and returned to the plant on June 27,2007, because the documented corrective actions did not reflect the actions taken andother actions were incomplete. NCR 06-02 relates to what the licensee originallycharacterized as an unexplained significant increase in the liquid radioactive waste tankactivity. At the time of the inspection, the quality verification staff was reviewing thisNCR to verify closure of all required actions.2.3ConclusionsThe licensee's safety review program was conducted in compliance with 10 CFR 50.59requirements. The licensee had established and implemented a non-conformanceprogram that was in compliance with Quality Assurance Plan requirements.3.0Spent Fuel Pool Safety (60801)
3.1Inspection ScopeThe inspector reviewed the licensee's control of the SFP to ensure compliance withTechnical Specifications requirements and Defueled Safety Analysis Report (DSAR)commitments. 3.2Observations and FindingsThe inspector conducted a tour of the SFP area and reviewed plant records to ensurethe safe storage of the fuel and other irradiated items in the pool. TechnicalSpecifications 3.1.1 states that the SFP water level shall be at an elevation of greater-7-than 10.5 feet. At the time of the inspection, the water level was 10.80 feet. Theinspector also confirmed that the low water level alarm was set at 10.67 feet as requiredby the DSAR.Technical Specifications 3.1.3 states that the SFP liner water level shall be at anelevation less than +9 inches (0.75 feet). The liner water level was -0.04 feet during theinspection. The inspector also confirmed that the licensee was monitoring both SFPlevel and liner water level at the frequencies established in Technical Specificationssurveillance requirements.To prevent inadvertent drainage of the SFP, the licensee had sealed the stop valve onthe SFP drain, removed the piping beyond the stop valve and placed a blind flange onthe pipe stem. On July 11, 2007, the inspector toured the pipe gallery area and verifiedthat these were the conditions of SFP drain. The inspector also verified that procedureHBAP C-9 #1 listed the SFP drain stop valve as a sealed or locked valve.
Section 2.3.1.1 of the DSAR states that two sources of makeup water will be maintainedfor the SFP. The inspector interviewed operations staff personnel and determined thatthe two waters sources were the demineralized water storage tank and fire water. TheDSAR specifies that a minimum of 2,000 gallons shall be maintained in thedemineralized water storage tank. The demineralized water storage tank level indicatordisplays tank level in inches. The 2000 gallon limit amounts to 53.5 inches. On July 13,2007, the tank level was 73.0 inches or 4149 gallons. In addition, the fire water systemwas available for emergency supply of water.Table 5.2 of the DSAR provides the limits for SFP water chemistry and radioactivitylevels. Details of this requirement were documented in site procedure STP 3.6.5,"Monthly Spent Fuel Pool Water Quality Check," Revision 44. The pool water wasroutinely sampled for pH, conductivity and cesium-137 activity. The inspector reviewedthe plant records for March 29, 2006 through June 20, 2007. The licensee had collectedpool water samples on a monthly frequency as required by the DSAR and had analyzedthe samples for the required chemical constituents. Since March 2006, all parametersremained within DSAR limits.The licensee continued tracking the SFP demineralizer differential pressure. TheRadiation Protection Manager stated that if current trends continued it was unlikely thatthe resins would need to be replaced prior to fuel transfer to the independent spent fuelstorage installation (ISFSI). During sorting of irradiated components in the interim storage containers, the licenseestaff located 9 small items that it appear to be fuel pellet fragments. The licensee staffconcluded that these fragments were originally on the energy absorber, and had beenmoved to an interim storage container when the energy absorber was removed from theSFP. The licensee was storing these items in a separate interim storage container. It isexpected that as cleanup of the SFP continues additional small fuel fragments will befound. Upon completion of the SFP cleanup these items and any additional suspectitems found would be evaluated to determine if they were fuel fragments and should bestored with other fuel fragments previously identified.
-8-3.3ConclusionsThe licensee was maintaining the SFP water level and water chemistry in accordancewith Technical Specifications requirements and Defueled Safety Analysis Reportcommitments.4.0Maintenance and Surveillan ce (IP 62801)4.1 Inspection ScopeThe inspector reviewed the licensee's maintenance and surveillance program forcompliance with the Maintenance Rule requirements, 10 CFR 50.65.4.2Observations and FindingsThe licensee's maintenance program remained generally as described in InspectionReport 05000133/2005003. Administrative procedures HBAP C-40, "MaintenanceProgram" and HBAP C-40 #1, "Maintenance Rule Compliance," described the licensee'sprogram for complying with the Maintenance Rule. The licensee had identified 17Structures, Systems or Components (SSCs) that were subjected to the MaintenanceRule. The licensee had developed surveillance test procedures (STPs)
to monitor theSSCs subject to the Maintenance Rule as required by 10 CFR 50.65(a)(1). The inspector reviewed the licensee method to assure the timely conduct of STPs. Thelicensee used administrative procedure HBAP C-3#2, "Scheduling of Plant andEquipment Tests" for keeping the STP schedules updated and for issuing the weeklyreminders to the test coordinators. The STP schedule and weekly reminders weremaintained in paper records. The licensee was testing a computer based system toupdate the STP schedule and to generate the weekly reminders.The STP schedule had been maintained. 4.3ConclusionsThe licensee had implemented a maintenance program that met the requirements of theMaintenance Rule provided in 10 CFR 50.65.
5.0Decommissioning Performance and Status Review (IP 71801)5.1 Inspection ScopeThe inspector conducted tours of the site to evaluate whether facility conditions werebeing effectively controlled during SAFSTOR. 5.2Observations and FindingsThe inspector toured the fuel handling building, the Unit 3 control room, and other areasof the facility. Radiological postings were visibl e and met the r equirements of 10 CFR Part 20. Housekeeping and facility conditions were effectively controlled. Most-9-of the areas in the facility were free of radiological contamination and we re accessiblewithout the need of protective clothing. No safety concerns were observed during thetours. The control room indicators associated with monitoring SFP water and liner levelswere confirmed to be functional.5.3Conclusions Radiological conditions of the facility were properly posted. Housekeeping and facilityconditions were effectively controlled. 6.0Occupational Radiation Exposure (IP 83750)
6.1Inspection ScopeThe inspector reviewed the licensee's recent radiation protection program audit and theirradiological occurrence reporting system. The inspector interviewed the radiationprotection manager and the radiation protection engineer to determine if any of the changes that had been made to the organization, personnel, facilit ies, equipment,programs, or procedures since the last inspection had a negative affect on occupationalradiation protection. The licensee's personnel radiation monitoring program andassociated reports submitted were inspected for compliance with applicable regulatoryrequirements and commitments. 6.2Observations and Findings a.Audits and Appraisals10 CFR 20.1101 required each license to conduct, at least annually, a review of their radiation pr otection program c ontent and implementation. The controlling procedure forconducting this review is Humboldt Bay Administrative Procedure HB-C200,"Requirements for the HBPP Radiation Protection Program." The inspector reviewed EDMS #062500018, the biennial audit of the RadiationProtection, Radioactive Materials Packaging and Transportation, and Radioactive WasteProcessing and Process Control Program. This audit was performed October 9through 20, 2006. The individuals that conducted the audit were independent of theHBPP organization and did not report to any managers at HBPP. This audit identified7 quality problems and made 17 recommendations. The licensee had opened problemreports (SAP Notifications) for all quality problems and recommendations identified in theaudit. The licensee had addressed the quality problems and recommendationsidentified in the audit and had completed all of the actions.To document and evaluate identified radiation protection deficiencies, the licensee hadestablished the Radiological Occurrence Report (ROR) system. This program wasguided by Radiation Control Procedure RCP-2F, "Radiological Occurrence Reports." The ROR system classified occurrences as Level 1 or Level 2. Level 1 is minorradiological occurrences that may be below the threshold for a plant problem report. Level 2 is radiological occurrences that violated procedures, policies and NRC directivesor that require a higher than Level 1 attention. Records maintained by the licensee-10-indicated that 31 RORs were issued in 2006 of which 8 were Level 2. As of July 10, 2007, six RORs had been initiated in calendar year 2007 of which 2 were Level 2. TheLevel 2 RORs were identified as Level 2 because they required a higher attention thanLevel 1, such as assigning dose to an individual. None of the Level 2s were the result ofviolated procedures, policies nor NRC directives. The licensee had effectively followedits process for reporting, documenting, and evaluating radiological occurrences. b.ChangesThere had been no changes in organization, since this area was last reviewed during theMarch 27-31, 2006, inspection. The licensee had added three senior radiationprotection technicians and one decontamination technician as temporary additions tosupport the pool cleanup work and the independent spent fuel storage installationproject.The licensee had acquired three new digital telescoping detector radiation instrumentsfor site use. New operating and testing procedures were been developed and would beimplemented prior to placing these instruments into service. Four radiation control standards and 41 radiation control procedures had been revised,or had been initially issued since this area was last inspected in September 12-14, 2005. The inspector selected two standards and three procedures for review. The reviewsindicated that procedure changes implemented by the licensee provided improvementsor clarifications for the existing procedures. The inspector concluded that theseprocedure changes had a positive effect on the program. c.External and Internal Exposure Control and Other Radiation Protection Inspection AreasThe inspector interviewed the Radiation Protection Engineer and Dosimetry Coordinatorabout the occupational radiation exposure control program, and examined occupationaldosimetry records from January 1, 2006, through June 30, 2007. The records indicatedthat no individual had been classified as a declared pregnant worker and that noplanned special exposures had been conducted. The licensee used thermo luminescent dosimeters (TLDs) provided by the DiabloCanyon Nuclear Power Plant. Diablo Canyon was accredited under the NationalVoluntary Laboratory Accreditation Program for the type of dosimeters used. Thisaccreditation is valid through September 30, 2007. During calender year 2006, the licensee had monitored 143 individuals with TLDs forexternal radiation exposure and 41 individuals with breathing zone air samples forinternal exposures. During calendar year 2006, there were 17 incidents of personnelcontamination and 2 in 2007 as of July 10. Not all personnel contaminations resulted indose being assigned to the individual. When dose assignment was required thelicensee used Varskin Model 2 computer code to evaluate the dose associated with theskin contamination. The cumulative total effective dose equivalent (TEDE) during 2006for all individuals monitored was 4.086 rem; 4.002 rem from external exposure, deepdose equivalent (DDE) and 0.084 rem to internal exposure or committed effective doseequivalent (CEDE). CEDE was calculated based on the results from breathing zone air-11-samples results. The individual with the highest exposure during calendar year 2006received 0.658 rem TEDE, 0.649 rem DDE and 0.009 rem CEDE. The highest CEDEwas 0.030 rem. During calender year 2006, other dose measurements for shallow dose,lens of the eye dose, and extremity dose were all below applicable limits. The licensee identified two cases where the ratio of TLD to electronic dosimeter (ED)readings for an individual radiation worker wearing the two dosimeters during the sameperiod differed by more than 25 percent. A problem report was initiated that was stillopen. Preliminary results of the evaluation found that during the first quarter of 2007when comparing TLD vs ED in about 70 percent of the TLD results were higher than theED. The licensee is continuing to evaluate the reason for this discrepancy, but believesthat it was due to not applying a geometry factor to the ED. All doses assigned werebased on the TLD readings6.3ConclusionsThe audit of the radiation protection program conducted in 2006 met applicablerequirements. The licensee's radiological occurrence report system had properlydocumented and evaluated radiation protection deficiencies. The inspector concludedthat changes made to the number of personnel, equipment, and changes proceduressince the last inspection had a positive effect on occupational radiation protection. Thelicensee was maintaining an effective program to control and monitor occupationalradiation exposures. 7.0Radioactive Waste Treatment and Effluent and Environmental Monitoring (84750)
7.1Inspection ScopeThe inspector interviewed cognizant personnel and reviewed selected documents todetermine if any significant changes had been made by the licensee that affected (1) thelicensee's liquid and airborne radwaste, water chemistry, and radiological environmentalmonitoring organization or (2) the offsite dose calculation manual (ODCM). Theinspector reviewed the status of radioactive waste process and effluent monitors. The2006 Annual Radiological Environmental Monitoring and the 2006 Annual RadioactiveEffluent Release Reports were reviewed. 7.2 Observations and Findings a.Audits and AppraisalsAs noted in Section 6.1a above, the inspector reviewed EDMS #062500018, the biennialaudit of the Radiation Protection, Radioactive Materials Packaging and Transportation,and Radioactive Waste Processing and Process Control Program. This audit wasperformed October 9 through 20, 2006. The individuals that conducted the audit wereindependent of the HBPP organization and did not report to any managers at HBPP. This audit identified 7 quality problems and made 17 recommendations. The licenseehad opened problem reports (SAP Notifications) for all quality problems andrecommendations identified in the audit. The licensee had addressed the quality-12-problems and recommendations identified in the audit and had completed all of theactions. b.ChangesThis area was last inspected March 27-31, 2006. There had been no significantchanges made to the site radiological monitoring organization. The licensee lastupdated the ODCM to Revision 13, on March 2, 2007. This change has not yet beenformally reported to the NRC. It will be reported with issuance of the Annual RadioactiveEffluent Release Report for 2007. This change to the ODCM was required to addresschanges to the radwaste system. A new Radioactive Liquid Effluent Monitoring Systemwas declared operation on March 19, 2007. New components incl uded scintillationdetector, analyzer, activity monitor, system indications including alarms, high alarm tripfeature, and power supply. The only components not changed in the Radioactive WasteLiquid Effluent Monitoring System were the radioactive check source, liquid sampler andthe associated piping. b.Process and Effluent MonitorsSection 2.1 of the ODCM specified that the radioactive liquid effluent monitoringinstrumentation shall have at least one channel of gross radioactivity monitoringproviding the capability to automatically terminate the effluent release based on grossactivity at all times. The surveillances for this instrument included daily channel check,quarterly source check and functional test, and annual channel calibration. As notedabove a new Radioactive Liquid Effluent Monitoring System was declared operationalon March 19, 2007. The inspector reviewed selected records of surveillances performedon this instrument and concluded that the instrument was being maintained as requiredby the ODCM. The instrument was last calibrated on March 2, 2007, and wasoperational at the time of the site visit. During the revision of the ODCM, the licensee staff identified an error on the formulaused for setting the Radioactive Liquid Effluent Monitor (RLEM) alarm. A problemreport, SAPN 1242451, was opened to evaluate this problem. The evaluation concludedthat this error could have resulted in liquid releases exceeding the 10 CFR Part 20Appendix B limit only if an inadvertent discharge with no circulating water pumpsoperating occurred. The licensee reviewed their records and determined that noinadvertent discharges had occurred and all discharges had at least one circulatingpump operational. c.Annual Radiological Environmental Monitoring Report for 2006Technical Specification 5.7.2 required that an Annual Radiological EnvironmentalMonitoring Report be submitted to the NRC prior to May 1 covering the previouscalendar year. On April 30, 2007, the licensee submitted the 2006 report. This reportindicated that direct radiation, surface water, and groundwater and were being monitoredas required. Airborne, ingestion and terrestrial pathway monitoring was not required bythe ODCM. The environmental report submitted as part of the SAFSTOR licenserequest established baseline conditions for those pathways. The licensee monitorsdirect radiation at 16 locations onsite. The onsite locations were slightly higher this year-13-than in previous years. The licensee attributed the slight increase to the movement andstorage of radioactive resin onsite. Radioactivity levels in other sampled media wereconsistent with previous years and all results were below the NRC required reportablelevels. a.Annual Radioactive Effluent Release Report for 2006Technical Specification 5.7.3 required that an Annual Radioactive Effluent ReleaseReport be submitted prior to April 1 of each year. In accordance with 10 CFR 50.36(a),the report must cover the activities of the previous calender year. On March 28, 2007,the licensee submitted the 2006 Annual Radioactive Effluent Release Report on a timelybasis. The report included summaries of radioactive gaseous and liquid releases fromthe site. The report concluded that the releases of radioactivity in gaseous and liquideffluents were well below the 10 CFR 50 Appendix I numerical as low as reasonablyachievable (ALARA) guidelines and that the maximum potential direct radiation dosealthough slightly increase over previous years remained well below the limits of10 CFR 20.1302(b)(2(ii).There were no abnormal gaseous or liquid releases during 2005. There were eightliquid batch releases during 2006 and no continuous liquid releases. There were nobatch gaseous releases during 2006. In 2006, no solid radioactive waste was disposed.
The ODCM was not revised during this 2006. 7.3ConclusionsThe audit of the radiation protection program, which included the effluent andenvironmental monitoring conducted in 2006 met applicable requirements. The offsite dose calculation manual was revised in March 2007. A new RadioactiveLiquid Effluent Monitoring System was installed and declared operational March 2007. The radioactive waste process and liquid effluent monitors were operational, properlycalibrated and were being maintained as specified in the offsite dose calculation manual.The Annual Radiological Environmental Monitoring and the Annual Radioactive EffluentRelease Report for calender year 2006 were submitted on a timely basis and metapplicable requirements. Radioactivity levels in the sampled media were generallyconsistent with previous years and were below the NRC required reportable levels. Thereleases of radioactivity in gaseous and liquid effluents in 2006 did not exceedapplicable regulatory limits.8.0Exit MeetingOn July 13, 2007, at the conclusion of the site visit, the inspector presented to the plantmanager and other licensee staff members the preliminary results of the inspection. Thelicensee did not identify as proprietary any information provided to, or reviewed by, theinspector.
ATTACHMENT 1SUPPLEMENTAL INSPECTION INFORMATIONPARTIAL LIST OF PERSONS CONTACTEDLicensee Personnel:
J. Albers, Radiation Protection ManagerC. Caldwell, Unit 3 SupervisorJ. Chadwick, Senior Radiation Protection EngineerJ. Davis, Radiation Protection EngineerZ. Easley, Security SupervisorG. Bierbaum, Design EngineerV. Jensen, Quality Control SupervisorG. Mason, Quality Assurance SupervisorL. Sharp, Director and Plant Manager - NuclearL. Pulley, ISFSI ManagerM. Smith, Engineering ManagerD. Sokolsky, Licensing SupervisorR. Sorensen, Programs CoordinatorR. Willis, Plant Manager FossilINSPECTION PROCEDURES USEDIP 36801 Organization, Management, and Cost ControlsIP 37801 Safety Reviews, Design Changes, and ModificationsIP 60801 Spent Fuel Pool SafetyIP 62801 Maintenance and SurveillancesIP 71801 Decommissioning Performance and Status ReviewIP 83750 Occupational Radiation ExposureIP 84750 Radioactive Waste Treatment, Effluent and Environmental Monitoring ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed None Discussed None-2-LIST OF ACRONYMSALARAAs Low As Reasonably Achievable CAPR Corrective Actions to Prevent Recurrence CEDE Committed Effective Dose EquivalentCFHCertified Fuel HandlerDDE Deep Dose EquivalentDSAR Defueled Safety Analysis ReportED Electronic DosimeterHBAP Humboldt Bay Administrative ProcedureIPInspection ProcedureLBIE Licensing Basis Impact EvaluationNCRs Non-Conformance ReportsNSOC Nuclear Safety Oversight Committee ODCM Offsite Dose Calculation Manual PSRC Plant Staff Review CommitteeRLEM Radioactive Liquid Effluent MonitorROR Radiological Occurrence ReportSAPNSAP Notification (Problem Report)SFPSpent Fuel PoolSSCs Structure, System or ComponentsSTPs Surveillance Test ProceduresTEDE Total Effective Dose Equivalent TLDs Thermo Luminescent Dosimeters ATTACHMENT 2PARTIAL LIST OF DOCUMENTS REVIEWEDAudits and Appraisals*EDMS # 062500018, HBPP Radiation Protection, Radioactive Materials Packaging andTransportation, and Radioactive Waste Processing and Process Control Program Auditreport, performed October 10 through 20, 2006, report approved November 10, 2006.Corrective Action Program Documents (SAPN & Nonconformance Reports)*Corrective Action Program Report SAPN 1242451, Discrepancy between the ODCMcalculations used for setting the Radioactive Liquid Effluent Monitor (RLEM) alarm andthe basis for the calculations.Procedures*Humboldt Bay Administrative Procedure (HBAP) A-1, HBPP Organization and StaffQualifications," Appendix 6.4, Revision 25, effective September 7, 2006.*Humboldt Bay Administrative Procedure HBAP C-3 #2, "Scheduling of Plant andEquipment Tests," Revision 21B, effective April 5, 2007.*Humboldt Bay Administrative Procedure HBAP C-19, "Licensing Basis Impact Evaluation(LBIE)," Revision 21, effective March 31, 2006.*Humboldt Bay Administrative Procedure, HBAP C-40, "Maintenance Program," Revision 18, effective July 12, 2007.*Humboldt Bay Administrative Procedure, HBAP C-40 #1, "Maintenance RuleCompliance," Revision 4, effective January 11, 2007.*Humboldt Bay Radiat ion Control Standard HBRCS-2, "Controlling Total Effective DoseEquivalent As Low As Reasonably Achievable," Revision 8, effective March 23, 2007.*Humboldt Bay Radiation Control Standard RCS-12, "Respiratory Protection Program,"Revision 3, effective March 23, 2007.*Humboldt Bay Radiation Control Procedure RCP-2D, "Evaluation of Internal Depositionof Radioactive Material," Revision 30, effective December 1, 2005.*Humboldt Bay Radiation Control Procedure RCP-2F, "Radiological Occurrence Reports,"Revision 7, effective September 16, 2002.*Humboldt Bay Radiation Control Procedure RCP-4I, "Occupational Exposure Reporting(NRC Form 5)," Revision 2A, effective May 11, 2006.
-2- Data Sheets*List of Certified fuel Handlers as of July 12, 2007.*Attachment 10.1, Surveillance Test Procedure 3.21.4, Radioactive Liquid EffluentMonitor Source Check, Calibration, and Channel Functional Test, Revision 43,performed March 2, 2007.*Attachment 8.1, Surveillance Test Procedure 3.21.3, Weekly Radioactive Liquid EffluentMonitor Checks, Revision 46, performed March 2, March 6, March 8, March 13,March 19, March 20, March 22, and March 27, 2007.Reports*Annual Radioactive Effluent Release Report for 2006, HBL-07-004, March 28, 2007.
- Annual Radiological Environmental Monitoring Report for 2006, HBL-07-009, April 30, 2007.