IR 05000133/2008002

IR 05000133-08-002 on 04/07 - 04/11/08 for Humboldt Bay Power Plant, Unit 3, Review of Solid Radioactive Waste Management and Transportation of Radioactive Materials

ML081720594
Person / Time
Site:	Humboldt Bay
Issue date:	06/18/2008
From:	Whitten J NRC Region 4
To:	Conway J Pacific Gas & Electric Co
References
IR-08-002
Download: ML081720594 (12)

Text

UNITED STATES NUC LE AR RE G UL AT O RY C O M M I S S I O N une 18, 2008

SUBJECT:

NRC INSPECTION REPORT 050-00133/08-002

Dear Mr. Conway:

A special NRC inspection was conducted on April 7 through 11 and May 2, 2008, at your Humboldt Bay Power Plant Unit 3 facility. This inspection was an examination of activities conducted under your license as they relate to safety and compliance of the Commissions rules and regulations and with the conditions of your license. Within these areas, the inspection included reviews of your solid radioactive waste management and transportation of radioactive materials. On April 11, 2008, at the conclusion of the first site visit an exit interview was conducted with Mr. Loren Sharp, Director and Plant Manager and other members of your staff.

On May 29, 2008, after review of additional information a telephonic exit was conducted with Mr.

Loren Sharp, Director and Plant Manager. The enclosed report presents the scope and results of that inspection. The inspection determined that you were conducting decommissioning activities in compliance with regulatory and license requirements.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/Adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction.

Should you have any questions concerning this inspection, please contact Mr. Emilio Garcia, Health Physicist, at (530) 756-3910, or the undersigned at (817) 860-8197.

Sincerely,

/RA/

Jack E. Whitten, Chief Nuclear Materials Safety Branch B Docket No.: 050-00133 License No.: DPR-7

Pacific Gas and Electric Company -2-

Enclosure:

NRC Inspection Report 050-00133/08-002 (w/Attachments 1 & 2)

REGION IV==

Docket No.: 050-00133 License No.: DPR-7 Report No.: 050-00133/08-002 Licensee: Pacific Gas and Electric Company Facility: Humboldt Bay Power Plant, Unit 3 Location: 1000 King Salmon Avenue Eureka, California 95503 Dates: April 7 through May 29, 2008 Inspectors: Emilio M. Garcia, Health Physicist Nuclear Materials Safety Branch B Approved By: Jack E. Whitten, Chief Nuclear Materials Safety Branch B Attachments: Supplemental Inspection Information Partial List of Documents Reviewed Enclosure

EXECUTIVE SUMMARY Humboldt Bay Power Plant, Unit 3 NRC Inspection Report 050-00133/08-002 The Humboldt Bay Power Plant (HBPP), Unit 3 was shutdown in 1976. The facility has been in a SAFSTOR status since shutdown with minimal decommissioning activity occurring at the site.

This special NRC inspection was conducted to review the practices and procedures used by the licensee during the Resin Disposal Project and the licensees activities to dispose of residual irradiated components from the spent fuel pool (SFP). The inspector reviewed the licensees procedures and observed selected portions of the licensees operations in processing, packaging, and preparing for shipment contaminated resins and miscellaneous and irradiated hardware from the HBPP SFP.

Solid Radwaste Management & Transportation of Radioactive Materials The licensee had successfully loaded, packaged, moved, and shipped the contents in the Resin Disposal Tank and miscellaneous waste and irradiated hardware from the SFP. The inspector concluded that these activities were conducted in a safe manner and in accordance with licensees procedures and applicable regulatory requirements. Personnel radiation exposures were below the licensees dose projections for these activities (Section 1).

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Report Details Summary of Plant Status The HBPP, Unit 3, is currently in decommissioning SAFSTOR status. Unit 3 received an operating license from the Atomic Energy Commission on August 28, 1962. On July 2, 1976, Unit 3 was shutdown for annual refueling and seismic modifications. This work was suspended by the licensee in December 1980 and in June 1983 Pacific Gas and Electric Company (PG&E)

announced its intention to decommission the unit. Unit 3 has been essentially in SAFSTOR since July 1985. On July 19, 1988, NRC approved the PG&Es SAFSTOR plan and amended the license to a possess-but-not-operate status. The license will expire on November 9, 2015.

The facility has undergone minimal decommissioning activity since shutdown. During this inspection, the inspector reviewed the licensees preparations and practices for transferring, packaging, and shipping of the contents of the Resin Disposal Tank (RDT) and the removal and disposal of the remaining irradiated hardware and fission chambers stored in the SFP.

1.0 Solid Radioactive Waste Management and Transportation (86750)

1.1 Inspection Scope The inspector reviewed the licensees procedures for transferring, packaging and shipping the contents of the RDT. Additionally, the inspector reviewed the licensees preparations for removing resins from the RDT, observed portions of a wet run conducted by the licensee prior to transferring resins to a waste container, and observed portions of the transfer of the radioactive waste contents from the RDT to the second waste container filled by the licensee. The inspector reviewed the licensees preparations for the removal of irradiated hardware and fission chambers from the SFP.

1.2 Observations and Findings a. Transfer, Packaging and Shipment of RDT Contents The licensee addressed the transfer, packaging, shipping, processing, and the eventual disposal of the contents of the RDT by initiating a special project. Licensee records reviewed by the inspector noted that the RDT contained spent resin used in the SFP water demineralizer, activated charcoal, and inorganic oxides. The contents of the RDT were highly contaminated. The waste material in the RDT contained fission and activation products and transuranic nuclides. Licensee surveys records, reviewed by the inspector, recorded contact dose rates outside of the RDT of 2.8 R/hr. The special project that was implemented by the licensee tracked actions required to safely transfer the radioactive waste to containers (waste liners), package the waste liners in a shipping cask, and transport the resulting package to a volume reduction process contractor.

After volume reduction of the radioactive waste material by the volume reduction contractor, the resulting materials would be sent for disposal at a low-level radioactive waste disposal site. The licensee originally estimated that the RDT contained approximately 980 cubic feet of solids and would require six or seven waste liners be filled. The loading of the waste liners was restricted by the amount of transuranics that the volume reduction contractors license would allow the contractor to possess at any one time. The licensee, before making any shipments to the volume reduction-3- Enclosure

contractor, had secured the assistance of experienced contractors who were familiar with the transfer and packaging of the highly contaminated resin and with the specific requirements of the volume reduction contractors license.

The licensee issued SAP notification (SAPN) Number 1245621 to track activities associated with the removal and disposal of the radioactive waste residing in the RDT.

(SAP software vendors name that provided the tracking system.) This SAPN tracked the work associated with transferring the solids and water to the RDT, receipt and inspection of all needed components to transfer and package the radioactive waste materials for disposal, modifications made to plant structures, the shipment of radioactive materials to the volume reduction contractor, and other miscellaneous task that might occur during this special project.

The inspector noted that the Liquid Radwaste Treatment Building (LRWTB) had been modified by the licensee to include a larger rollup door and the installation of a Load Module System. These modifications permitted the loading of the waste liners with the highly contaminated RDT contents inside the controlled environment of the LRWTB.

During the loading and dewatering of a waste liner containing the highly contaminated resins, the liner would be located inside a 16-inch concrete walled, shielded, storage container that is referred to by the licensee as the Secure Environmental Container (SEC). The purpose of the SEC was to effectively shield occupational workers from the radiation generated by the contaminated resins in the waste liner. After transfer and dewatering the waste liner, the licensee moved the waste liner and the SEC by air pallet on the Load Module System to the outside of the LRWTB. Once outside of the LRWTB, the licensee then used a crane to remove the waste liner from the SEC and place it inside the transport cask.

The licensee developed temporary Procedure (TP) 2008-01, Transfer of the Contents of the RDT for Processing and Disposal. The first revision of this procedure was reviewed and approved by the Plant Staff Review Committee and issued with an effective dated of March 7, 2008. Prior to the development of TP 2008-01, another TP was developed, TP 2008-06, Temporary Procedure for Dry Runs of the Transfer of the Contents of the RDT for Processing and Disposal. Lessons learned from this dry run procedure were incorporated in the operating procedure.

The actual transfer procedure TP 2008-01, required the licensee to make test runs during the transfer, dewatering of the resins, and fillport equipment checks using clean water sources. During these wet runs, problems were identified by the licensees contractor with the fillport connection that resulted in the licensee rejecting several waste liners. The waste liner vendor eventually determined that a communication error between the vendor and fabricator of the waste liner dewatering connection had resulted in improper connections being installed in the waste liners. Had the licensee not conducted wet test runs before loading the highly contaminated resins the licensee would not have been unable to dewater the waste liners as originally planned.

During the April 7 - 11, 2008, site visit the inspector observed the licensees receipt of new waste liners with the correct dewatering connections, installation of fall protection equipment, portions of the wet runs, and portions of the RDT contents transfer of contaminated resins to the second waste liner. The inspector in observing the resin-4- Enclosure

transfer project noted the use of checklists, good communication between the licensees and contractors staff, procedural adherence, and close control of licensed activities between workers and the radiation protection technicians.

The licensee had issued special radiation work permit (SWP) 2008-116, Transfer of the RDT Resin into Liners and Liner Handling Including Leak Repair, Liner Change Out, Resin Transfer, Liner Handling, and Associated Work. This SWP specified the requirements for continuous radiation protection coverage, the maximum permissible radiation dose rates, and the maximum contamination limits. The inspector observed the licensee providing continuous radiation protection coverage, donning of specified dosimetry and protective clothing, and enforcing the maximum contamination limits.

The licensee prepared an as low as reasonably achievable (ALARA) dose estimate for this SWP that projected a dose of 430 person-millirem. This estimate was based on six waste liners being loaded. Due to the actual lower volume of contaminated resins in the RDT, 585 ft3 vs. 980 ft3, only four waste liners were required. The actual average dose per liner was 64 person-millirem where the projected dose had been about 70 person-millirem per waste liner. The inspector noted that the actual doses decreased for each subsequent loading of waste liners. The doses observed by the licensee ranged from 112.4 person-millirem for the first waste liner to 35.7 person-millirem for the fourth waste liner.

On April 10, 2008, the inspector reviewed the shipping records prepared by the licensee for the first waste liner shipped offsite (RMS-08-011), and on May 2, 2008, the inspectors examined the records of the additional three shipments, RMS-08-013, RMS-08-014, and RMS-08-17. The inspector noted in reviewing the shipment records that the licensee had used a certified cask Model 14-212, USA DOT 7A Type A casks for the transport of each of the waste liners. The records maintained by the licensee included the NRC Form 540, Uniform Low-Level Radioactive Waste Manifest, for each shipment and was signed by a trained and designated authorized licensee representative. The shipping records also included copies emergency response instructions, exclusive use instructions, waste profile and waste classification information, corresponding waste package surveys, and corresponding tractor and trailer radiation surveys. The waste was classified by the licensee as Type C. The inspector verified the 24-hour emergency telephone number listed on the shipping papers. Shipping documents also included transportation permits for each of the States through which the transport vehicle was schedule to traverse.

The inspector concluded that the transfer, packaging and shipments of the RDT contents were conducted in a safe manner and in accordance with licensee procedures and applicable regulatory requirements.

b. Transfer and Disposal of SFP Waste In preparation for the relocation of the reactor spent fuel to the Independent Spent Fuel Storage Installation (ISFSI), the licensees staff was continuing a campaign to remove and dispose of miscellaneous and irradiated hardware stored in the SFP. Based on high levels of alpha contamination in the SFP and the licensees need to move the highly irradiated hardware outside the pool with limited shielding, this activity was categorized-5- Enclosure

by the licensee as having a potential of exposing personnel to high radiation exposures.

During this inspection the inspector observed the licensees preparations for the removal of the irradiated hardware from the SFP.

The inventory of the radioactive materials to be removed from the SFP included segments of Fission Chambers and tubes, chards from the fuel channels, and a few pieces of satellite balls and roller pins. Due to the high radiation levels, the licensee planned to place this material in a lead lined drum (LLD) that had been fabricated. The LLD was designed by the licensee to accommodate a basket where the irradiated components would be placed before removal from the SFP. Once the radioactive materials were loaded into the basket, they were to be lifted from the SFP, excess water allowed to drip, and then placed inside the LLD that had been preloaded with absorbent material. Following the loading activities, the LLD would then be sealed and moved by the overhead crane to an area near the newly installed davit crane. Because of the location of the davit crane, the LLD could not be directly loaded into the transport cask.

The licensees plans required that a truck mounted crane be brought into the building to perform the final lift of the LLD into the transport cask.

The complexity of the plan was well understood by the licensees staff. To prepare for the loading and moving of the LLD, and the ultimate placement of the LLD into the transport cask, the licensee had conducted and a number of dry runs to optimize the time required to conduct these operations and minimize the radiation dose to personnel.

During the site visit of April 7-11, 2008, the inspector observed an ALARA review meeting and underwater surveys of the loaded basket taken by the licensees staff. The actual transfer of the LLD into the transport cask occurred later in the month.

To track the personnel doses due to the disposal operations occurring in the SPF, the licensee had issued a special radiation work permit SWP-2008-0117 to perform this work. The ALARA estimate made by the licensee had identified 10 specific steps and had projected that it would result in an exposure of 530 person-millirem and 120 person-hours. The licensees post job ALARA review indicated that the actual exposure was 99 person-millirem and 89 person-hours.

On May 2, 2008, the inspector reviewed the records made for SFP irradiated materials shipment, RMS-08-016. This shipment was made by the licensee on April 26, 2008.

Records maintained by the licensee included an NRC Form 540, Uniform Low-Level Radioactive Waste Manifest, signed by a trained and designated authorized licensee representative. The shipping records also included copies of emergency response instructions, exclusive use instructions, waste profile and waste classification information, associated package surveys, and the corresponding tractor and trailer radiation surveys taken by the licensee. The waste was classified by the licensee as Type C. The inspector verified that the listed 24-hour emergency telephone number identified on the shipping papers. The shipping documents also included transportation permits for each of the States through which the transport vehicle was schedule to traverse.

The inspector concluded that the loading, packaging, movement, and shipment of SFP miscellaneous waste and irradiated hardware had been conducted in a safe manner and in accordance with licensee procedures and applicable regulatory requirements.

-6- Enclosure

1.3 Conclusions The licensee had successfully loaded, packaged, moved, and shipped the RDT contents and the miscellaneous waste and irradiated hardware from the SFP. The inspector concluded that these operations had been conducted in a safe manner and in accordance with licensee procedures and applicable regulatory requirements.

Personnel radiation exposures were noted by the inspector as being below the licensees dose projections.

2.0 Exit Meeting On April 14, 2008, at the conclusion of the site visit, the inspector presented to the Director and Plant Manager and other licensee staff members, the preliminary results of the inspection. On May 29, 2008, after review of additional information a telephonic exit was conducted with the Director and Plant Manager. The licensee did not identify as proprietary any information provided to, or reviewed by, the inspectors.

-7- Enclosure

ATTACHMENT SUPPLEMENTAL INSPECTION INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel:

J. Albers, Radiation Protection Manager C. Caldwell, Operations Supervisor J. Chadwick, Senior Radiation Protection Engineer J. Davis, Radiation Protection Engineer V. Jensen, Quality Control, Training and Programs Coordinator K. Rod, Decommissioning Manager P. Roller, Operations Manager L. Sharp, Director and Plant Manager M. Smith, Engineering Manager D. Sokolsky, Licensing Supervisor Contractor Personnel:

A Berry, Project Manager - AM Solutions P. Davin, Project Manager - Enercon INSPECTION PROCEDURES USED IP 86750 Solid Radwaste Management & Transportation of Radioactive Materials ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed None Discussed None Attachment

LIST OF ACRONYMS ALARA as low as reasonably achievable DOT Department of Transportation PG&E Pacific Gas and Electric Company HBPP Humboldt Bay Power Plant IP inspection procedure ISFSI independent spent fuel storage installation LLD lead lined drum LRWTB liquid radwaste treatment building RDT resin disposal tank RMS radioactive materials shipment SEC secure environmental container SFP spent fuel pool SWP special radiation work permit TP temporary procedure-2- Attachment