IR 05000133/1997002

Insp Rept 50-133/97-02 on 970513-0911.Violations Noted.Major Areas Inspected:Organization,Mgt & Cost Controls,Employee Concern Program,Decommissioning projects,10CFR50.59 SE Program,Annual Environ Rept Reviews & Maint & Surveillance

ML20217D657
Person / Time
Site:	Humboldt Bay
Issue date:	10/01/1997
From:	Spitzberg D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20217D622	List: IR 05000133/1997002 ML20217D619 ML20217D638
References
50-133-97-02, 50-133-97-2, NUDOCS 9710060051
Download: ML20217D657 (42)

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ENCLOSURE 2 U.S.: NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50 133 License No.: .DPR 7 Report No.: 50 133/97 02 Licensee: . Pacific Gas and Electric Company

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Facility: Humboldt Bay Power Plant Unit No. 3 (HBPP 3)

Location: 1000 King Salmon Avenue Eureka, California 95503 Dates: May 13 through September 11,1997 Inspectors: J. V. Everett, Health Physics Inspector R. F. Dudley, NRR Project Manager

. Accompanied By: Ellis W. Merschoff, Regional Administrator Mark F. . Hammond, Public Affairs Officer Approved By: D. Blair Spitzberg, Ph.D., Chief

' Nuclear Materials inspection and Fuel Cycle / Decommissioning Attachment: Supplemental Information 9710060051 971001 gDR ADOCK 05000133 PDR . - - . ~~., - - - - - -.. - - _.- - - --- . _-.

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2-EXECUTIVE SUMMARY Humboldt Bay Power Plant,' Unit No. 3 NRC Inspection Report 50 133/97 02 This inspection implemented the new and recently issued inspection manual and procedures for permanently shutdown plants. The licensee's programs that were reviewed as part of this inspection were being implemented effectively to maintain the SAFSTOR status of the facility. Humboldt Bay had been in SAFSTOR for 20 years. The facility had been maintained in an adequate state of preservation, with the exception of the leakage of groundwater into the reactor caisson. This in-leakage had become a problem after three earthquakes in April 1992. The in-leakage prior to the earthquakes had been 150-200-gallons / day. This level was considered insignificant. However, after the earthquakes, the levels began to rise, eventually reaching a peak of over 9,000 gallons / day in the fall of; 1996. The licensee had been tracking the problem closely and evaluating various contingency actions, in November 1996, the licensee initiated a repair project to decrease or stop the in-leakage. On September 11,1997, the licensee informed the NRC that the project had been completed and the leak had been reduced to less than 10 gallons / da Oroanizetion,Jdanaaement. and Cost Controls

. The licensee's decommissioning organization, staffing, qualifications, and training were found to be in compliance with the decommissioning plan and Technical ,

Specificationc. All management positions were staffed by personnel who excecded the required qualification requirements (Section 11,

. The training program for new employees, radiation workers, contract personnel, and certified fuel handlers was adequately documented, implemented by an assigned : '

training coordinator, and in compliance with the requirements of the Technical Specifications (Section 1).

Emolovee Concern Program i

j .. The licensee's employee concern program provided employees and contractors an

opportunity to report safety and quality problems. The licensee had recently 4 conducted meetings with employees and distributed a questionnaire to assess and

!-  : promote the program (Section 2).

Decommissioriina Projects

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I . The licensee maintained the Humboldt Bay Unit No. 3 facility in a SAFSTOR

L condition as described in its decommissioning plan and Technical Specifications, No problems were noted related to plant structures and housekeeping (Section 3).

. The licensee was in the process of injecting grout into the floor of the west

suppression chamber to reduce or stop the in-leakage problem, Work controls had

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3-been established for the grouting operation. The NRC was notified on September 11,1997, that the repair effort had been successful and the in-leakage had been reduced to negligibie levels (Section 3).

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Contingency procedures had been drafted and were being fir.alized should the repair effort for the in leakage be unsuccessful or the leak was to recur resulting in a leakage rate that exceeded the capacity of the existing removal or processing systems (Section 3).

10 CFR 50.59 Safetv Evaluation Program

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Acceptable programs were being implemented to ensure that activities, changes, tests, and experiments were properly evaluated for compliance with NRC requirements in 10 CFR 50.59 and that no unreviewed safety questions were involved with such activities (Section 4).

Annual Environmental Reoort Reviews

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The 1996 Annual Radiological Effluent Release Report and the 1996 Annual Facility Status and Survey Report were reviewed and found to comply with the requirements of Technical Specification Vll.H. Effluent radiologicallevels due to plant activities during 1996 wore within the limits of 10 CFR Part 20 for airborne and liquid releases (Section 5).

Maintenance and ! _ u

. The setting of the liquid radwaste process monitor alarm exceeded a Technical Specification setpoint limit during the period April 815,1997, thereby reducing the level of conservatism of a key system used to prevent releases of radioactive liquids into the discharge canal. No release occurred above 10 CFR Part 20 limits. This was identified as a violation (Section 6).

Follow-uo of Ooen Iterns

. On April 25,1997, water was trancierred from the demineralized water tank to the spent fuel pool resulting in the water level in the tank dropping below the Technical Specification limit of 2000 gallons. The water level was promptly reestablished and corrective actions taken to prevent recurrence. This non repetitive, licensee identified and corrected violation is being treated as a non-cited violation (Section 7).

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All corrective actions related to the 1996 violation for discharging contaminated water from the liquid radwaste system have been completed. This open item is closed (Section 7).

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Incorporation of an " alert" classification into the emergency plan and development of emergency action levels for an alert have been completed. This open item is closed (Section 7).

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5-Report Details Summarv of Plant Status The Humboldt Bay Power Plant, Unit 3 had been shutdown and placed in SAFSTOR since 1976. The Decommissioning Plan was approved by the NRC in 1988 and under the 1996 revision to t;.e decommissioning rules, is considered to be a Post Shutdown Decommissioning Activities Report. The 390 spent fuel assemblies onsite are stored in the spent fuel pool. Plant staffing consisted of 66 employees and contractors plus an additional 45 contractors assigned to the caisson in leakage repair project. Work had progressed on the caisson in-leakage repair project to inject grout into the rock layer of the

reactor caisson floor to reduce or stop the in-leakage. The baffle plates had been removed i from the east and west suppression chambers; the suppression chambers had been

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decontaminated and painted; ventilation ducts, lighting, and a false ceiling had been installed; and doors had been established between the two suppression chambers and the drywell. In-leakage was averaging about 6,500 gallons / day. On September 11,1997, the licensee informed the NRC that the grouting project to stop the in-leakage had been completed end the in-leakage rate had been reduced to less than 10 gallons / day. This was a substantial reduction and indicated that the efforts to reduce the leak were initially successfu During this inspection, presentations were made to the NRC inspector and the Regional Administrator concerning the efforts underway to repair the in-leakage. This included a review of the techniques being utilized to stop the leak, the rationale and analysis for selecting the grouting, and the tests and mockups that had been performed to validate the planned process, in addition to discussions on the in leakage repair project, presentations were mada concerning earthquake / tsunami potential for the site, recent public information concerning the site that had been printed in various newspapers, and decommissioning strategies that could be options for the Humboldt Bay facility in the future. Handouts were provided during the meetin Organization, Management, and Cost Controls (36801) Insoection Scone The licensee's decommissioning organization, staffing, qualifications, and training were reviewed and evaluate .2 Observations and Findinas The site organization, staffing, and qualifications were found to meet the requirements described in the approved decommissioning plan and Technical Specifications. The Humboldt Bay Technical Specifications, Section Vil, established the requirements for the site orcanization. Humboldt Bay Procedure HBAP A-1#1, HBPP Statf Organization, Revision 4, dated January 24,1997, included several organization charts with lines of authority. The Plant Manager was responsible for

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-6-approving changes to the site organization. Over the past 2 years, the licensee had increased the site staffing level, Severalindividuals from the licensee's San Francisco office had been transferred to the Humboldt Bay site to support the in-leakage project and the planned stack removal project. The group included personnel for licensing, quality assurance, and public affair Procedure HBAP A-1, HBPP Staff Organization and Qualifications, Revision 9, dated August 14,1997, established key position descriptions, qualifications, I

responsibilities, and lines of authority. The Plant Manager was responsible for the day-to-dsy safe operations of site activities. Staff qualifications were established for the F, ant Manager, Assistant Plant Manager, Supervisor of Operations, Radiation

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Protection Manager, Supervisor of Maintenance, Quality Control Supervisor, l Technical Manager, and Certified Fuel Handlers. Qualification requirements included l minimum years of experience and required technical knowledge. The requirements established in procedure HBAP A 1 were equivalent to the requirements established in Technical Specifications section Vll.C.2. A detail review of individual resumes and qualifications was completed for the current Plant Manager, Assistant Plant Manager, Supervisor of Maintenance, Supervisor of Operations, Technical Manager, Radiation Protection Manager, and Quality Control Supervisor. All individuals exceeded the requirements for their assigned position Procedure HBAP A 1 included a task analysis for selected key positions of the licensee's organization. The task analysis provided detailed descriptions of the expected activities associated with each position. Major work responsibilities were ider tified with associated work activities liste The Humboldt Bay Emergency Plan, Revision 26, effective August 1,1997, described the normal and emergency organizations in Section 5.0. A notification call-out was listed in order of priority in Section 6.1.1.4. The titles used in the emergency plan were found to be consistent with the position titles of the current licensee's organization. Staffing levels appeared to be sufficient for the types of emergency conditions identified in the emergency plan for the site. Lines of communications and responsibilities were defined for the key emergency organization member The training program for new employees and for the certified fuel handlers was reviewed and found to be adequate. The program was implemented by an assigned site training coordinator. The new employee training program provided for both initial training and annual refresher training for both employees and contract personnel. An initial employee check-in form was completed for each employee which identified the work areas to which the individuals may be assigned. Based on the work areas, individuals were assigned to one of six categories related to whether an individual would need access to the office areas only, restricted area, Unit No. 3 control room, refueling building, or would bo wearing a respirator. Each category had specific training requirements. Higher levels of training were required

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7-for individuals who would be involved with radiological activities compared to persons assigned to office areas onl Technical Specification Vll.C.4 established the training requirements for the certified fuel handler program. All training course requirements identified in the Technical Specification Vll.C.4 were specified in Section 3.1.3.b of Procedure HBAP B-100 and were confirmed by the training coordinator as being part of the current progra Technical Specification Vll.C.4 required a two year cycle for requalification. The licensee conducted annual training of the certified fuel handlers and requalification every 2 year Training records for selected management personnel required to be certified fuel handlers per Technical Specification were reviewed. Allindividuals were found to meet the requirements. This included the positions of Plant Manager, Assistant Plant Manager, Supervisor of Operations, and Technical Manager. The licensee also maintained five shif t foremen and eight senior control operators as certified fuel handler .3 Conclusion The licensee's decommissioning organization, staf fing, qualifications, and training were found to be in compliance with the decommissioning plan and Technical Specifications. All management positions were staffed by personnel who exceeded

- the required qualification requirement The training program for new employees, radiation workers, contract personnel, and certified fuel handlers was adequately documented, implemented by an assigned training coordinator, and in compliance with the requirements of the Technical Specification Employee Concern Program (3S801) Jnsoection Scone The effectiveness of the licensee's employee concern program was reviewed and evaluate .2 Observation and Findinos The employee concern program at Humboldt Bay was adequate for the level of activity underway at the site. The program was administered by PG&E's Nuclear Power Generation Nuclear Quality Services Department. The program encompasses both Diablo Canyon and Humboldt Bay. Procedure OM3.1D3, Employee Concern Program, Revision 6, dated June 4,1997, defined the PG&E employee concern program. The procedure covered responsibilities fo the program, processing and tracking concerns, and conducting investigaticns. The Hu.nboldt Bay quality control

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supervisor was the onsite contact for the employee concern program and assisted employees and contractors in implementing the employee concein process. Since 1995, only one employee concern had been reported. The low number of reported concerns was attributed by the licsasee to the small and stable work force that nad existed at Humboldt Bay for the past several years. Communication between workers and management appeared to support ongoing reporting of problems through normallines of authority. A tour of verious work areas found numerous postiras for the employee concern program which provided the quality hotline phone number. The inspector cailed the posted number which was quickly answered by a responsible person in the licensee's quality assurance progra >

In February 1997, the licensee hired an outside consultant to conduct an independent assessment of the company's nuclear power generation employee concern program and the overall safety culture at PG&E. The licensee's facilities at Diablo Canyon, Humboldt Bay, San Francisco, and San Ramon were included in the assessment which was completed in July 1997. The assessment included evaluation of the employee concern program and procedures, day-to-day implementation of the program, interviews with selected employees, and distribution of a written survey to all nuclear power generation employees. Eight-hundred I

responses were received from the survey, of which 42 were from Humboldt Ba Overall, the consultant found the PG&E errpioyee concern program to be a strong program, comparing favorably with other programs in the nuclear industr The assessment found that when a clear safety issue was involved, employces felt little or no hesitation to stop work and bring the concern to the attention of their immediate supervisor. There was, however, concern expressed about raising issues where the safety connection was less certain. Employees did not want to be labeled as complainers making them vulnerable to future downsizing. There was also concern noted over raising issues that the employee felt their supervisor could not do much about. Over half of the employees felt uncomfortable about taking concerns to management over their supervisor. Even though the PG&E program encouraged employees to report problems, the consultant concluded that feedback to employees concerning the resolution of the problem was a weakness, in March 1997, a training course entitled " Managing for Nuclear Safety" was conducted at Humboldt Bay, Licensee personnel, contractor foremen and contracter superviso% attended. On April 9,1997, an all employees meeting was held and the emoloyee concern process discussed. The Humboldt Bay plant manager issued a-memo on April 10,1997, which re-enforced the importance of the employee concern program at Humboldt Ba .3 Conclusion The licensee's employee concern program provided employees and antractors an opportunity to report safety and quality problems. The licensee had recently

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conducted meetings with employees and distributed a questionnaire to assess and promote the progra Decommissioning Projects (71801)

3.1 Insoection Scone The licensee's performance related to maintaining the site in an acceptable condition of SAFSTOR, as described in the decommissioning plan and Technical p

Specifications, was reviewed and evaluated. Work activities were observed related to the current effort to reduce or stop the in-leakage problem in the reactor caisso A plant tour was conducted to evaluate facility structures and housekeeping.

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3.2 Observations and Findinas l The licensee had continued to maintain the Hur ooldt Bay Unit No. 3 facility in a SAFSTOR condition as described in the appre ad dr, commissioning plan and l Technical Specifications. A tour was condi cted rsf several areas of the site i

including the Unit No. 3 reactor building ca sson control room, and radwaste building. The facility appeared adequately .naintained and in reasonably good condition. Plant housekeeping was good. No hazardous work conditions or fire hazard problems were observed, in order to maintain the Humboldt Bay facility in a SAFSTOR condition, PG&E had been faced with a number of decisions related to deterioration of structures at the site. This included the caisson in leakage problem, clogC i ng of piping, and cracks in the tall stack located adjacent to Unit No. 3. The most immediate problen involved the in-leakage of water into the lower level of the reactor caisson. Work activities related to the in leakage repair project were observed during this inspection, including injection of the grout into the first section of the west suppressior, chamber floor. The tests conducted on t, number of mock-ups prior to actual injection were also examined. These tests helped establish the most effective injection techniques and set times for the grout. Good work controls had been established in the reactor caisson work areas, including confined space entry

) restrictions. During the plant tour, personnel responsible for dosimetry and access to the confined space area ensured that members of the tour had complied with procedural requirements while in the are The in-leakage problem in the reactor caisson started in 1992 after three earthquakes in April. Prior to the earthquakes, the in-leakage rate was 100-150 gallons / day and was not considered a problem. However, increasing levels of in-leakage were recorded after the earthquakes and levels continued to rise over the years, eventually reaching 9,000 gallons / day during October 1996. Soon afterwards, the in leakage began decreasing and remained at 6,000 to 8,000 gallons / day. During the week of August 26-28,1997, the in-leakage level averaged 6,500 gallons / day. The licensee was faced with a significant challenge to

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- 10-find the location of the leak ender the reactor caisson floor and implement corrective actions to seal the leakin s area. A contract was issued to locate and repair the lea The project had been underway since October 1996. Schedules and work packages had been developed for the pro,iect. Work activities were coordinated closely with the NRC to provide sufficient notice to facilitate NRC observation of activitie During this inspection, the grouting activities were initiated on the first of eight sections in the west suppression chamber floor. On September 11,1997, the licen;ee informed the NRC by telephone of the status cf the repair project. Grouting had ueen completed on Saturday, September 6,1997. By Monday, the water rerr. fining in the drainage layer under the floor had drained and it appeared that only minor additionalleakage was ocaurring. As of September 11,1997, the in-leakage

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continued to be negligible, indicating the reoair project had been successful, inspection to:lowup item 50-133/94001-03 was opened in 1994 to track the leak problem and will remain open until the next inspection to verify that the leak repair is stable. If the leak rate continues to be negligible, this open item will be closed.

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' in response to the in leakage problem, the licensee had developed a comprehensive Emergency Contingency Procedure entitled "FCA 1, Loss of Control of the Reactor Caisson Sump." This procedure was in draf t during this inspectinn, although the staff had cornpleted the procedure review process and planned to issue the procedure in September. The procedure provided for contingency actions should the in-leakage rate increase to the point that the existing pumping capacity and discharge syster e in the caisson would be exceeded. Though this procedure was a draf t, it was reviewed as part of this inspection to verify that adequate contingency preparations were being made should the in-leakage repair project be unsuccessful or a future earthquake or other event re-establish the leak at a greater rat .3 Conclusion The licensee had maintained the Humboldt Bay Unit No. 3 facility in a SAFSTOR condition as described in its decommissioning plan and Technical Specifications. No problems were noted related to plant structures and housekeepin The licensee was in the process of injecting grout into the floor of the west suppression chamber to reduce or stop the in leakage problem. Work controls been established for the grouting operation. The NRC war notified on September 11,1997, that the repair effort had been successful and the in leakage had been reduced to negligible level Contingency procedures had been drafted and were being finalized should the repair effort for the in-leakege be unsuccessful or the leak was to recur resulting in a leakage rate that exceeded the capacity of the existing removal or processing system _ _ - - -

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11-4 10 CFR 50.59 Safety Evaluation Program (37001) Insnection Scnce A review was performed of selected documentation of activities, changes, tests, and experiments to verify that proper evaluations were completed for compliance with NRC regulations in 10 CFR 50.59 and that no unreviewed safety questions were involved with such activities. This portion of the inspection was conducted May 1315,199 .2 Observations and Findinas

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On July 29,1996, the NRC revised its decommissioning regulations to codify the use of 10 CFR 50.59 by licensees of perrnanently shut down power reactors.

l Humboldt Bay is thus required to maintain a functional safety review program that l

controls f acility design changes, modifications, procedure chances, tests, and (

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experiments in accordance with 10 CFR 50.59. The recent rule change also added new requirements in 10 CFR 50.82(a)(6) that preclude licensees from performing decommissioning activities that:

(i) Foreclose the release of the site for possible unrestricted use; (ii) Result in significant environmental impacts not oreviously reviewed; or (iii) Result in there no longer being reasonable assurance that adequate funds will be available for decommissionin Regarding the new requirements in 10 CFR 50.82(a)(6), the inspector could not identify any current licensee procedures which would ensure that all decommissioning activities are evaluated for compliance with 10 CFR 50.82(a)(6)

xafore they are undertaken. The inspector recommended that such procedures apphcable to all decommissioning activities be established by the licensee. The licensee is evaluating this recommendatio The licensee's administrative procedures for performing safety evaluations were reviewed. Selected safety evaluations that hao seen completed between 1995 and early 1997 were audited and found to meet the requirements of 10 CFR 50.5 Licensees are allowed to make changes to the Part 50 reactor programs and facilities using the provisions of 10 CFR 50.59, provided that the changes do not involve an unreviewed safety question. Humboldt Bay had implemented Procedure HBAP C-19, Revision 4, "10 CFR 50.59 Safety Evaluations," to provide guidance to staff personnel performing these evaluations. This procedure required that a screening evaluation (Attachment 7.1 to HBAP C-19) be conducted to determine whether a 10 CFR 50.59 safety evaluation must bo performed for an activity. In cases where safety evaluations must be performed, Attachment 7.2 of HBAP C-19 must be completed in order to determine whether the proposed activity involved an unreviewed safety question which would then require prior NRC review and approval. All screening evaluations must be reviewed by an independent

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-13- Obstivations and Firidsgs The 1996 annual reports for effluent releases, facility status, monitoring were reviewed and found to comply with the requ, Specification Vll.H. The licensee was required by Technical Si submit to the NRC within 90 days of January 1 of each year an describing the results of the environmental and facility radiation ;

status of the facility. The licensee submitted to the NRC on Marc reports to satisfy the Technical Specification requirement. The 19, Radioactive Effluent Release Report complied with the requirements 10 CFR 50.36(a) and summarized the gaseous and liquid radioactive s released from Humboldt Bay Unit No. 3 for 1996. The 1996 Annual F and Survey Report for 1996 provided a summary of environmental mon results for 1996 and the status of the facilit The Annual Radioactive Effluent Release Report was reviewed to determint radiologicallevels due to plant activities were within the limits of 10 CFR Pa airborne and liquid relea9s Since Humboldt Bay had been shutdown for 20 the radiologicallevels had decayed substantially and short-lived isotopes were longer detectable. The primary isotopes monitored in the effluents were Cs-13 Co-60, Sr-90, Kr-85, tritium, and gross alpha. Regulatory Guide 1.21 'dentifies t lower limits of detectability for vanous isotopes. The licensee used thosc limits f(

establishing counting process of various samples. Tritium and Kr-85 were not detected in the gaseous effluents. Cs.137, Sr 97, and Co-60 were detected. The licensee calculated that the amount of radioisotopes released during 1996 were more than one million times below the release limits of 10 CFR Part 2 l

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For liquid effluents released from the site, tritium was detected; however, the 1 l

quantities were also calculated to be over one million times less than NRC limit '

Co-60 and Cs-137 were also measured. These levels were higher, averaging less than 0.0015 percent of the NRC limit During 1996, the licernee made three shipments of radwaste to offsite facilitie The shipments consisted of ccataminated materials and dewatered sludge. Total curies shipped were less than 1.31 x 104 curie The Annual Facility Status and Survey Report was reviewed to evaluate the results i for the environmental monitoring program for 1996. The licensee provided information related to the caisson sump sampling program. Monthly sampling detected no alpha or beta activity above background in the caisson water being released. Only one sample was found to have detectable gamma radiation above the minimum detectable activity of 10 pCi/ liter. The sample was 10.3 6.5 pCillite The licensee maintained environmental monitoring stations with thermoluminescent do.;imeters limo) in compliance with Technical Specification V.A.4, V.A 6 and _ - - . - - - - _ - _ - - _ - - - - - _ - - - - - - - - - - - - --

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-12-technical reviewer and all safety evaluations must be reviewed by the Plant Staf f Review Committee and the Nuclear Safety Oversight Committee. The procedure also required that persons who prepare or independently review screening evaluations or 10 CFR 50.59 safety evaluations must have completed overview

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training on the safety e sluation process and on humboldt Bay licensing basis documents. The licenseds procedure was appropriate in that it properly guided preparers of safety evaluations to determine whether an unreviewed safety question was involved in proposed activities.

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Brief reviews of the screening evaluatioris and the safety evaluations for the following activities were completed:

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DCN HB3 EP-381, " Elimination of Fuel Pit Drain Line to Core Spray Pump Suction" l

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Temporary Procedure dated November 10,1995, No. 2, " Decontamination of Reactor Caisson Sump"

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DCN HB3 SE-383, " Provide Power to Power Panel 1 from Emergency Section l of MCC 10"

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DCN HB3 SM-401, " Add Discharge Capacity to Reactor Caisson Sump, Phase 1"

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Temporary Procedure dated February 22,1996, " Gravity Feed Test - Demi Water Tank to Spent Fuel Pool"

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SAFSTOR Equipment Removal Authorization HB3-007, " Remove Low Pressure Core Flooding Piping Betwee 1 + 12 and -14 foot Elevation" All safety evaluations reviewed were prepared in accordance with the appropriate procedure and were adequate and in compliance with applicable NRC regulation .3 Conclusion Acceptable programs were being implemented to ensure that activities, changes, tests, and experiments were properly evaluated for compliance with NRC requirements in 10 CFR 50.59 and that no unreviewed safety questions were involved with such activitie Annual Environmental Report Reviews (84750,80721,90713) Insoection Scoce The 1996 Annual Radiological Effluent Release Report and the 1996 Annual Facility Status and Survey Report were reviewe ,

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-13- .Qbiervations and Findinas The 1996 annual reports for effluent releases, facility status, and environmental monitoring were reviewed and found to comply with the requirements of Technical Specification Vll.H. The licensee was required by Technical Specification Vll.H.1 tosubmit to the NRC within 90 days of January 1 of each year an annual report

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describing the results of the environmental and facility radiation surveys and the status of the facility. The licensee submitted to the NRC on March 28,1997, two reports to satisfy the Technical Specific 3 tion requirement. The 1996 Annual

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Radioactive Effluent Release Report complied with the requirements of 10 CFR 50.36(e) and summarired the gaseous and liquid radioactive effluents

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released from Humboldt Bay Unit No. 3 for 1996. The 1996 Annual Facility Status and Survey Report for 1996 provided a summary of environmental monitoring results for 1996 and the status of the facilit The Annual Radioactive Effluent Release Report was reviewed to determine if radiologicallevels due to plant activities were within the limits of 10 CFR Part 20 for airborne and liquid releases. Since Humboldt Bay had been shutdown for 20 years, the radiological levels had decayed substantially and short-lived isotopes were no longer detectable. The primary isotopes monitored in the effluents were Cs-137, Co-60, Sr 90 Kr 85, tritium, and gross alpha. Regulatory Guide 1.21 identifies the lower limits of detectability for various isotopes. The licensee used these limits for establishing counting process of various samples. Tritium and Kr 85 were not detected in the gaseous effluents. Cs 137, Sr 97, and Co-60 were detected. The licensee calculated that the r. mount of radioisotopes released during 1996 were more than one million times below the release limits of 10 CFR Part 2 For liquid effluents released from the site, tritium was detected; however, the quantities were also calculated to be over one million times less than NRC limit Co-60 and Cs-137 were also measured. These levels were higher, averaging less than 0.0015,oercent of the NRC limit During 1996, the licensee made three shipments of radwaste to offsite facilitie The shipments consisted of contaminated materials and dewatered sludge. Total curies shipped were less than 1.31 x 104 curies.

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The Annual Facility Status and Survey Report was reviewed to evaluate the r6sults for the environmental monitoring program for 1996. The licensee provided information related to the caisson sump sampling program. Monthly sampling detected no alpha or beta activity above background in the caisson water being released. Only one sample was found to have detectable gamma radiation above the minimum detectable activity of 10 pCilliter. The sample was 10.316.5 pCillite The licensee maintained environmental monitoring stations with thermoluminescent do.simeters (TLD) in compliance with Technical Specification V.A.4, V.A.6 and

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V.B.6 b. Four offsite environmental monitoring stations were required by Technical Specification V.A.4. Technical Specification V,A.6 required sixteen onsite dosimeters. The onsite dosimeters averaged 13.1 mR/ quarter with a range of 11.9 to 16.2 mR/ quarter. The offsite dosimeters averaged 12 mR/ quarter with a range of 11.1 to 14.2 mR/ quarter. All dosimeters were replaced quarterly. No unusual readings were noted and all readings were comparable with past env.ironmental radiation level Technical Specification V.A.6 and V.B.6.a required continuous sampling of the water in the discharge cancl. The licensee maintained a continuous composite sampler for the discharge canal. Samples were collected from the composite sampler and analyzed weekly. No gamma or tritium levels above background were measured. Gamma and tritium analysis indicated all samples were below the lower level of detection of 15 pC/l for Co-60,18 pCill for Cs 137, and 500 pCi/l for tritiu Technical Specification V.A.6 and V.B.6.c required monitoring of grrundwater. The licensee monitored five wells near Unit 3. The wells were sampled quarterly for gross alpha, gross beta, total gamma activity, and tritium. No gamma or alpha activities above minimum detectable activities were measured. The minimum detectable level for gross alpha was 3 pCi/l For gamma,15 pCill for Co-60 and j 18 pCill for Cs-137 were considered the lower level of detection. There were positive indications for gross beta exceeding the minimum detectable activity of 4 pCill on several occasions, but the levels were inconsistent from quarter to quarter. No well showed more than two quarters during the year with levels above the minirnum detectable activity. The highest beta reading was 37 *41 pCill fer well MW-11 located onsite just southwest of Unit No 3. This well was also found to have tritium levels above the 500 pCill minimum detectable activity for tritiu The well averaged 778 * 120 pCill. MW-11 has historically shown low, but detectable, tritium levels. As comparison to tha levels being detected at MW-11, the limit for tritium in drinking water established by the Environmental Protection Agency in 40 CFR 141.16 is 20,000 pCi/ .3 Conclusion The 1996 Annual Radiological Effluent Release Report and the 1996 Annual Facility Status and Survey Report were reviewed and found to comply with the requirements of Technical Specification Vll.H. Effluent radiologicallevels due to plant activities during 1996 were within the limits of 10 CFR Part 20 for airborne and liquid release * l

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- 15-6 Maintenance and Survaillance (B2tl01)

6,1 Insoection Scone On May 15,1997, the licensee issued Licensee Event Report (LER) 3-97-001 informing the NRC that the alarm setpoint on the liquid radwaste process monitor had been inadvertently set at a level higher than allowed by Technical Specifications for the period April 8-15,1997. This inspection reviewed the circumstances which led to the incorrect alarm setting and evaluated whether radioactive liquids had been released through the system exceeding 10 CFR Part 20 limit .2 Observations and Findinas The radwaste process monitor is an in-line system that monitors water being released into the discharge canal. The radwaste process monitor terminates any discharge of liquids if radioactive contamination is detected exceeding the high alarm setpoint.

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Technical Specification VI.B.1.a states that radioactive waste discharges to l Humboldt Bay shall not exceed the limits given in 10 CFR Part 20, Appendix B, Table 11, Column 2, on an instantaneous basis. Technical Specification V.B. states, in part, that the process water monitor shall be set to alarm at or below a Cs-137 concentration in the discharge line of 1 x 10 Ci/ml. Alarm functions and background readings shall be checked weekly, if a background reading exceeds the equivalent of 5 x 10' uCi/ml, the causo will be investigated and remedial measures taken to reduce the background readin The process monitor readout is in counts / minutes (cpm). The following settings were required for compliance with the Technical Specifict.tions. Normal background was 600-800 cp .

1 x 10~* uCi/ml equates to 31,200 cpm for the high alarm

=

b x 10~5 uCi/mi equates to 15,600 cpm for the warning alarm Two alarm setpoints were established for the process monitor by the license These alarm setpoints were established to be conservative with respect to the requirements of the Technical Specification. The warning alarm was set to 1500 cpm. The high alarm was set to 5000 cpm. Activation of the high alarm would turn off the discharge pump and terminate the releas Licensee Procedure STP 3.21.3, " Weekly Process Monitor Checks," had been used by the licensee to conduct tus weekly checks of the process monitor, as required by Technical Specification V.B.2. To perform this procedure, the operator mar.ually adjusted the alarm setpoints on the monitor alarm panelin the control room such that the alarm trip point was reduced to below the background level. This initiated the alarm. Af ter the test, the alarm setpoints were readjusted back to the required

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- 16-readings of 1500 and 5000 cpm. The process monitor readout in the control room had two scales, the 1 10,000 (10K) cpm scale and the 10-1,000,000 (1M) cpm scale. These two scales are located on the readout such that one scale is above the other scale. A se!ector switch was used to select the correct scale. The 1M scale was the correct scale for setting the 1500 cpm and 5000 cpm alarm point On April 15,1997, while a senior control operator was performing the weekly test of the process monitor, he discovered that the alarms had been set to 41,000 cpm and 300,000 cpm on the 1M scale. These alarm setpoints were obtained by using the 10K scale to set the 1500 cpm and 5000 cpm alarm points instead of using the 1M scale. The 41,000 cpm on the 1M scale corresponds to the 1500 cpm on the 1K scale. Likewise, the 300,000 cpm value on the 1M scale corresponds to the 5000 cpm reading on the 10K scale.

i Evaluation by the licensee determined that the monitor had been incorrectly set during the previous weekly test on April 8,1997. A review by the licensee of the strip chart recorder printout for the period the alarm was incorrectly set verified that l no radioactive liquids had been released into the discharge canal exceeding the i

Technical Specification limits. The strip chart recorder printout was re-evaluated by the NRC inspector during this inspection. The inspector confirmed that there was i no indication of any releases above normallevels.

l During the period the process monitor high alarm was incorrectly set, the system would have still alarmed and terminated a release before levels exceeded 10 CFR Part 20, Appendix B, as required by Technical Specification VI.B. The 300,000 cpm equated to 9.78 x 10-* uCi/mi at the release point into the discharge canal. The discharge canal mixes with other water, then empties into the bay. The 10 CFR Part 20, Appendix B, limit that applied to Humboldt Bay was 2.0 x 10~5 uCi/ml at the point where the discharge canal emptias into the bay. The licensee had performed analysis and documented the results in Procedure TSI 2,

" Technical Specification Interpretation: Caisson Sump Contamination," Revision 1, dated July 11,1997, where the alarm set point of 1 x 10'd Ci/ml was determined to equate to 2.4 x 104 pCi/ml at the point the discharge canal entered the ba Based on this value, the 300,000 cpm alarm set point would have equated to 2.3 x 10-euCi/mi at the point where the discharge canal entered the bay, which is below the 10 CFR Part 20, Appendix B limit of 2 x 10-5 uCi/mi limi The setting of the process monitor alarm above 1 x 10'd uCilml by the control operator during the weekly test of the process monitor is a violation of Technical Specification V.B.2.b. Though the alarm setting would have still terminated a release exceeding the limits of 10 CFR Part 20, Appendix B, the violation is of concern because it reduced the margin of conservatism for an important monitoring system (50-133/97002-01). '

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-17- Conclusion The setting of the liquid radwaste process monitor alarm exceeded a Technical Specification setpoint limit during the pariod April 8 15,1997, thereby reducing the level of conservatism of a key system used to prevent releases of radioactive liquids into the discharge canal No release occurred above 10 CFR Part 20 limits. This was identified as a violation, 7 Follow up of Open items (92700,92702)

L (Closedi LER 3 97-002: Demineralized Water Tank l

)

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On May 29,1997, the licensee submitted LER 3-97-002 informing the NRC that the level of water in the demineralizer water tank had dropped below the limit specified in Technical Specification IV.B.2.a On April 25,1997, plant operators responded to a low level alarm in the spent fuel pool by transferring water from the demineralized water tank to fill the spent fuel pool to its normallevel. Prior to transfer, the operators calculated the amount of water needed and determined that the demineralized water tank low level alarm would occur but that the water level would remain above the Technical Specification 1;mit of 2000 gallons. After the transfer was completed, the water levelin the domineralized water tank was determined to be 1900 gallons based on the gauge on the demineralized tan Prior to the transfer, the operators had determined that 3400 gallons were available in the domineralized water tank. The operators calculated that 1200 gallons would be needed for the transfer, leaving the levelin the tank at 2200 gallons. Tha operators recognized that the low level alarm for the demineralized water tank would be activated at 3070 gallons, however, they did not review the Low Leve:

Annunciator Alarm Guide ARG D-22 which contained an administrative limit that prohibited reducing the tank level below 2717 gallon and required operators to begin refilling the tank if the low level alarm occurre The process of transferring the 1200 gallons to the spent fuel poolinvolved the use of the circular chart recorder in the control room and a conversion table. Following completion of transferring the 1200 gallons of water, an operator went to the demineralized water tank and observed that the level gauge indicated 52.5 inches, which equated to 1900 gallons remaining in the tank. The operator began refilling the tank within 20 minutes. An investigation into the accuracy of the gauge was initiated and eventually determined that the gauge correctly indicated the tank's water level. Further investigation into the event revealed that a combination of the accuracy of the circular chart recorder and the additional use of water from the demineralized water tank by other plant personnel resulted in the water level dropping to 1900 gallon Corrective actions taken by the licensee inciuded returning the tank level above the 2000 gallon Technical Specification limit, issuing orders and discussing with I .

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-18-responsible personnel the requirement to stop draining water from the tank when the low level alarm occurs, and revising procedures to enhance the instructions to prevent re occurrence. The prompt recognition of the event and corrective actions taken by the licensee were considered in the evaluation ' this ever This non-repetitive, licensee identified and corrected violation is being treated as a non-cited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-133/97002-02).

7.2 (Closed) VIO 95003-01: Discharae of Contaminated Water Inspeu.;n Repor; 50-133/95-03, dated January 4,1996, identified a violation of Humboldt Bay Technical Specifications related to the discharge of contaminated water from the liquid radioactive waste system into the discharge canal. Progress in-completing the corrective actions for this violation had been dccumented in Inspection Reports 50-133/96-02 dated July 12,1996, and 50-133/97-01 dated

,

April 17,1997. The remaining requirements to comple;e training of the operating staff were verified as complete during this inspectio .3 (Closed) IFl 96002-01: Emeroencv Action Level a

The emergency planning program at Humboldt Bay had been reviewed during NRC inspection 50-133/94-03 in October 1994 and 50-133/96-02 in July 1996. Both inspections identified the possible need to add the " Alert" emergency classification into the Humboldt Bay program. PG&E conducted a review of the issue and deterrnined that incorporation of an " Alert" emergency classification into their program was appropriate. An effort was initiated to revise the emergency plan and procedures and to train site personnel. The revision and issuance of the revised emeigency plan and procedures, and training of perssnnel, was completed on August 28,1997. A significant number of changes were required and had been completed to incorporate the new classification level into the Humboldt Bay progra .4 Cnnetusion On April 25,1997, water was transferred from the demineralized water tank to the spent fuel pool resulting in the watar levelin the tank dropping below the Technical Specification limit of 2000 gallons. The water level was promptly reestablished and corrective actions taken to prevent recurrence. This non-repetitive, licensee identified and corrected violation is being treated as a non-cited violatio All corrective actions related to the 1996 violation for discharging contaminated water from the liquid radwaste system have been completed. This open item is closed, e

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Incorporation of an " alert" classification into the emergency plan and development of emergency action levels for an alert have been completed. This open item is closed, 8 Exit Meeting The inspector presented the inspection results to members of the licensee management at the exit meeting on August 28,1997. The licensee acknowledged the findings presented. The licensee did not identify as proprietary any information provided to, or reviewed by, the inspector.

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AUACliMENI I PARTIAL LIST OF PERSONS CONTACTED Licensee

A. Arago, Community Affairs

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L. Brown, Radiation Protection Consultant -

L Cluff, Geosciences Manager J. Crow, Training Coordinator M. Grossinan, Operations Supervisor V. Jensen, Quality Control Supervisor

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E. Kahler, Decommissioning Project Manager

B. Montalvo, P=&:lon Prottetion Foreman

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T. Moulla, Plant Van 6ger j R. Parker, Senior Engineer-

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1. Rasmussen, Senior Pnwer Production Engineer j M. Smith, Supervising engineer, Dry Cask Storage

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R. Sorensen, Staff Consultant

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O. Sokolsky, Senior Licensing Engineer D. Stetson, Quality Assurance Engineer 4 T. Tyler, Ma:ntenance Supervisor l R. Willis, Plant Engineer

C. Winfrey, Operations Shift Foreman

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INSPECTION PROCEDURES USED

36801 Organization, Management, and Cost Controls

' 37001_ -10 CFR 50.59 S:fety Evaluation Program 62801 Maintenance and Surveillance 71801 Decommissioning Performance and Status Review

! 80721 Radiological Environmental Monitoring 84750 i 90713 Radwaste Treatment and Effluent and Environmental Monitoring In Office Review of Periodic and Special Reports

92700 Ondte Follow up of Written Raports for Nonroutine Events l 92702 Muw up on Corrective Actions for Violations and Deviations

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ITEMS OPENED, CLOSED, AND DISCUSSED Onened i

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BO 133/97002 01 VIO incorrect Alarm Setting on Process Monitor 50-133/97002 02 NCV Demineralizer Water Tank Level

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2-ITEMS OPENED, CLOSED, AND DISCUSSED (Continued)

C101td 50 133/96002 01 IFl Emergency Action Level ,

50 133/95003 01 VIO Discharge of Contaminated Water  ;

50 133/97002 02 NCV Demineralizer Water Tank Level l

Discussed I

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50 133/94001 03 IFl Caisson Sump Inleakage  !

I LIST OF ACRONYMS- '

CFR Code of Federal Regulations HBPP Humboldt Bay Power Plant IFl Inspection Follow up ltem I LER Licensee Event Report mR milliroentgen .

mrem millirem NRC Nuclear Regulatory Commission i PG&E Pacific Gas & Electric *

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- TLD thermoluminescent dosirneters uCl microcurie f VIO Violation

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EMCLQSilBL3 PRESENTATION HANDOUTS FOR THE AUGUST 24,1997 BRIEFING ON HUMBOLDT BAY 1) Humboldt Bay Power Plant Earthquake Evaluation Progress Summary 2) Recent Print Media Articles Concerning Humboldt Bay Power Plant i

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I IIUMBOLDT BAY POWER PLANT EARTHQUAKE EVALUATION PROGRESS SUMMARY LLOYD S. CLUFF GEOSCIENCES DEPARTMENT AUGUST 26,1997 i. Background Earthquake Hazard Evaluations

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HUMBOLDT BAY POWER PLANT 1 4 l i

t RECENT PRINT MEDIA ARTICLES

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yt M 11ay landmark is emotrig dow vent stack as a guide to the bay entrance. But beaters say the

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racific Gas and ElectricCo.has .. : ,

applied to the state Public Ut2:ty Inutstana.Pacine Corp. smokes- ~- '-~

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- - - - - - - - -7 Commission to use part of its tack is also a good mar Alec Arago.put,ticaffa!rs cificer I,

decommissioning trust fund to pu!! down the vent stack at its for PGaE. said the stack must Tower erected In 1960s used as dnt for PG&E's now-decommis:

mothballed Ilumboldt Bay Nuc- come down because !!Is obsolete, 1 Jear Plant. The company has ab- deteriorating with age and a demoIIllon work could start in probably put la a construction hazar April 1998. Ile said it wCI c st an crane and bring 11 down in out $156 mlIllon In reserve to pieces." -

decommission the plant, which *!f an earthquake helps us take . estimated $4 m!H!cn. mesay for It down. It's going to cost us s lot disposalcfcontaminated matertal lie said about a quarter. nch of closed in 197 Since the plant was cen- more in the long run he sai and necessary safety precaution the stack's !nner surface could be structed in 19G3. small-boat op- If the FUC approves the expen- ~P.wont be a spectaculardyna- centaminated and will have to be crators have used the 250-foot , diture as expected. Arago said, mite explos!en.' he said. *We'll treated as radioacifre wast .

fugeu ' \ mes S> tar 0bAR.b

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stoned nuclear generator near King Salmo

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radioact#c dust from the air in The $20 mmion nuclear plant'* ; '

the nuclear storage area. Arago was closed after only 13 years.. ,

said its Stration technology is operatiou when it was found to ' ;

• crude' by present standani have beenbuilt on top of an act!ve .

He said it willbe replaced by a earthquake fault. But the reactor :

short steel stack with a mott u SeePG&E/A7  ;

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Thnes-S f Sunday, June 8,1997 s'

PG&Ebasemen tl eak v

proves costlyto plug ' ,

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too low to harm marine hfe, them outto thazanious waste sit . Tim T1 mas-Standard

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"Iben we had to move aH the

• ll "Ibert art only trace amounts e- things that were in the basement

- 1ENGSA!. ' %PacificGasand

! Electric Co. is nearing the end of a about one-10,000th of a merem a . aside,* he sali *Now we're looking

, f $9.5 mSon effort to ar aleakinits quarter in imimirr, (year),*

a chest X raybewf!1 satifTo putthat the lette arta.atDen a f!naldecontamination wet start sweep of basemen .-

l

. Company spokesman Alec Arago give you about 5 m@ rems, and a drang holes in the floor to find

' flight acoss the muntry 3 or 4 exactly where the leak is, g said work on the nudear powei marca *

plant, which' started in October, ' "Once we bolate n,wt*H probably

. abould be completed by mid Jul .

said about 7 gallons of A h h a he d b Just squirt n with grout" he sai *

Ihe actual pressure of th'e leak is

gro%un water a minute is leaking bbW W d n Whuetheleakusdfcan fatrtylaw, so we don't need a high-

8xed Ango reach-

. . into the rock Med cabson that hes 9

• atthebottom of the pitinwhich the ing it been a prt,blem.Wejob- tech solution."

nuclear itactor is suspended, about has required an outside cnntractor Angosaidthecompanybaskmg 78 feet undergmuni The leak re- emp! ytng about 45 people- the Pubhc IJtihties O=mi= ton to

{ suits from the age of the structure, 'authort:e payment of the $9.5 m$

he said, and may have been aggra- "It's a simple leak in a very inac- hon cost to repair the leak fmm its ak cessible comer of a s'Ah==n,nt demmm'**n'ng trust fund, along

vated by a 1993

. *1f we let it go dressed, it leakingtato subdoorundemeathan st.h the cost of demolishing the

could eventually overwhelm ourca- in.m.fble chamber.' he sali"We vent stack %e trust fund has ab .

P * packyito pump * be said.' . had to break through a 3 foot cnn . out $156 maca, coDected fmm

• Wafer from the caisson is crtte wa!!,then go tato an area that 1986 to 1990. Arago said the pre-

'. pump'e d out, monitored for conta. tion, hasdecontaminate eurface radioactive that area,contamin re- sent estimate of the cast of decom-mt**n'ng the whole plant, based

!m'nenn; and released through a move alot of existing'metalbagies, on a 1993 stuc'y, ts 1)103

dbcharge canalinto HumboldtBay, decontaminate them and move meo ' Aivgo said the radioactivtty level is

.

,

iPG&ErOLcMashionec c enerator cv oes on .

'FROM A1

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are lutely to remain here for years, and easier to maintai ; and spent fuel rods are stin stored at ingways if drytap storage unbe heensed

the site, and Arago said they wiu Arago said, PG&E is study %e rods tn earthquake country, he said, it

probably remain there for at least toare impruve their storag now stored in a pool of wate wt!1stinbe eve to 10 years before it

another decade, he most hkdy method, called is instaDed here, A planned nudear waste hne -

,

.at Yucca Mountain, Nev., has run drycap storage,he desertbed as *es . Amgo saidthecompanywincon-

, into obstacles, with first the Nevada sentiaDy a very sophisticated gar-

,

tinue to operate its comentional

stata government and now federal bage necan.*

.

15-foot-tall canisters, with generation plant at King Salmen .

' agenc!:s raising concerns about the safety of the site. Arago saidtoitact is as multiplebyen of sted and concrete which uses natural gas to generate a radioactivity shield, electricity,The plant is used primar

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unukdy to be open before 201 Questions have also been raised would probably be hung in frame- ily as abackup to supply electricity abouthowtheradioactivewaste can works to protect them against to Humboldt County when winter stmmabreakpowerunesrunningto I be safely transported to Nevad earthquake Ming Arago sai ~

They would be safer than the pool, the Central VaBe Because the reactorand fuciteds - __ - __ -

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CALIFORNIA ENERGY MARKETS *

June 6.1997, Page 6

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k (13) BOTTOM UNES: Thoughts on Leaky Nuclear Safety Enforcement e This week's top story is the product of wnter J.A. Savage's de6cated attention to nuclear power safety issues, particularly those related to Pacific Cas & Electnc's f acilities at Humboldt Bay and Diablo Canyon. Radioactrve water has been leaking from a below surface containment unit at the closed nuclear power plant since at lent 1993. Recently, the leaks have gotten worse--up to as much as 9,000 gallons each day. PC&E contractors are working fevenshly to stem the flows, but the work is difficult and costly-the utilit; is expected to, petition state regulators for use of $15 million in decommissioning funds to pay for the wor Humboldt Bay is one of the nation's oldest nudear plants, ccamissioned in 1963 and permanently closed on July 2,1976. PC&E's official story is that the facility went into a refueling cyc!e and never woke u The Nuclear Regulatory Commission says Humboldt Bay was shut down over seismic issues after it was discovered that several earthquake faults lay nearb In any event, the plant represents the "expenmental* phase of nudear power construction; PC&E told p Savage it was like building a nudear submarine in the ground. At Humboldt Bay, the expenment worked for 14 years and has lain dormant for more than 20 years. Because it has been off.line for so long, the plant has fallen out the public's normal field of attention. That is a mistak According to PG&E documents, the plan is for Humboldt Bay to be formally decommissioned in the year 2015. Currently, nudear fuel is stored on-site-in what the industry calls SAF5 TOR mode-unut the day when a federal waste repository becomes operational. No one really knows how long it will be before the unit can be dismantled, because the US government has been unable to site and certify a long. term disposal factirty for nuclear wast Though, PC&E and the NRC daim that plant equipment is -largely decontaminated of radioactNe material * there is still radioactrvity present, and the unit will remain a public concem as long as it stands.

l Usually, when a reporter can legitimately string the words nuclear, Icak, ocean and environment into a story, there is a cause for concem and quite a bit oT public attention. In this case, there has been little or no public nouce of the problem. A search of NRC reports available through the agency's otherwise comprehensive electronic data base shows no formal public not:ficat on by PC&E of the leaks at No one at any agency Humboldt Bay, appeared to assume any That seems odd, given the utility's generally commendable commitment to the environment and its direct promise to this responsibility, . newsletter that it will be 'proac0ve* In reporting on any safety issues related to nudear power (see CEM No. 404 [14]).

We may encounter an argument that this situation does not really involve safety. Savage's story includes a comment from a usually forthright NRC spokesperson indicating the agency sees the issue as *no big deal?

Again, this is odd. The NRC has very high standards for reporting of anything untoward at nuclear facilites-whether they are power plants or hospital labs. Just this week, staff at the now-closed Trojan nudear f acility in Oregon formally reported that two cups of diesel oil had washed into the nver. There was no radioactMty involved, and agencies determined that the spill was not a problem. But Trojan reported the incident to the NRC. In another report from the same day, a Michigan hospital said that it might have underdosed a patient with radioactive materials. So, the standards for notification dearly are quite stnc It is difficult to believe that a'substas.tialleak of radioactrve materialinto a marine environment should fall through the cracks of local, state and federal agencies. But no one at any agency that Savage talked to

. would assume any respornibiltty for overseeing problems at the plan CAUFORNIA ENERGY hwRKETS is not trysng to blow this story out of pioportion or implicate PC&E or term implicauons for the enforcement of piety the NRC in a cover up. But we are concemed about the long lives. Cunently, there are 17 nudear faciliti and monitoring of nudear facilities after they end their useful various stages of decommissioning; 10 have their nudear fuel stored on-site. In the coming decade, we expect as many as a score of other nudear units to cease operations because of economics in the new -

competitrve wodd, because of safety concems or because they have otherwise outltved their usefulnes _

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o Pagte 2 of 3 But the legacy of nuclear waste and contamination will stretch out for tens of thousands of year h As a society, we are in senous dental about our long term responsibilities for containing and monitonng' spent nuclear fuel and contaminated equipment. Our best response has been to dig a hofe in the ground and bury our problems beneath Yucca Mountain. But politics (or perhaps common sense) prevents even that solutio ;

We draw particular attention to Humboldt Bay because we hope that PC&E and govemment officials at alllevels can work together to solve the problem right away. Then, a joint study should be conducted to investigate the possible impacts on marine life in Humboldt Bay and on the human envtronment in the vicinity of Eurek But we insist it be done in a public manner, wthout minimizing the nsks invoked to the envuonment and wthout pretending it's *no big deal * [ Arthur O'Donneli].

114] WITH HUMBOLDT's REAGOR HOUSING LEAXINC kNTO BAY, PG&E SEEKS $15.2 MILLION FROM DECOMMISSIONING FUND (> from (ll) e A leaking reactor containment vessel is sending up to 9.000 gallons a day of radioactrve water into Humboldt Bay. 'We have a leak in our basement,' admitted Alec Arago, Pacific Cas & Electne spokesperson. Contractors have been working for months to plug the leaks'

but access to the underground structure is ddficu!t, and PC&E bebeves the job cannot be finished until July. '

The reactor sits 67 feet below sea level next to the bay in a concrete and steel sito. One of the nation's first commercial nuclear reactors, the plant was designed and built by engineers whose previous experience was building nuclear submannes "They basically ust built a submanne and put in the ground,* Arago sai The vessel began to leak a few hundred gal ons of coohng water per day in 199'l, according to Arag A year ago that amount rose to 2,000 gallons per day, and it is currently about 8,000 gallons a day, Arago said. An Environmental Protection Agency report in March, however, said the leak was up to 9,000 gallons each day. The source of the water is the bav the water is seeping through porous soil around the unit and entenng through numerous cracks into th'e containment silo. "When the tide goes out, so does the radioactmty," said one source who has been wrking on the lea The primary radionuclides (harmful radioacuve isotopes) leakir 4 into the bay are cesium 137 and strontium 90. Some of the effluent is caught arid sent through the uwity's radwaste processing, Arago sai The rock undemeath the vessel is contaminated at low, but measurable level Arago said any plutonium left in the reactor remains encapsulated and the spent fuel is stored in a separate on site fuel pool unaffected by the leak h PGLE self.monrtors the water quality on a monthl IF Engineer for the Regional Water Quality Control Board. y basis, according to john Hannum, That water board does little more than make sure PG&E's self monitoring reports come in. *We are not the gatekeeper of radionuclides,' Hannum declare PC&E's leak problem seems to have seeped into a govemmental black hole. No agency is out on Humboldt Bay with a Ceiger counter to follow up on the utility's self monitorin PG&E'sleakEroblem in addition to the water board, the state Erm,ronmental Protection Agency's Department of TexH Subtances noted that while there seems to have seeped

• may have been a release, it's not from the units we regulate.' into a govemmerital The federal Environmental Protection Agency said, "The EPA hu black hole, never been contacted by anyone for that plant,' according to spokesperson Paula Brui The Nuclear Regulatory Commission did check into the leak in April, *But it's not a big deal," said spokesperson Mark Hammond,"There are no violations from the radiological perspectrve,' he adde Last year, when the leak was about 2,000 gallons per day, PC&E reported contamination to the NRC at 1/40th of federal limits-0.5 picoeuries per millihter. The federal limit is 20 picoeuries/ milliliter. This year, in its report to the NRC when theleak had grown four fold, PC&E omitted corresponding contamination dat Opponents of nuclear power are skeptical about safety matters. 'For the utihty and the NRC to say something is safe, I don't believe them,'said Michael Welch, office coordinator of the Arcata based Redwood Alliance. *They should make extraordinary efforts to take as much radioactMty as possible out of the water."

Workers must cut through the under und steel and concrete and plug the leaks with what Arago called *high tech grout.' The steel is bein ipped to Tennessee for reprocessing. Other radioactive products, like bunny suits and rags, are shipped to ashington state. After decontarnination, some of PC&E's low-level waste materialis sent back for reus .

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This week, PC&f espects to (etition the Califemia Public Utdities Commission to use $1 million fro,

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its share of decommissioning truit funds for the reactor work.6;Of that,1 *

and $1,2 mdlion is for a site radiologeal survey. Currently, the estimated cost of decommissioning the pla *

a total of $103 mdlion by the due date of 2015, but that cost is espected to nse. The plant has Obeen shut l

'

down since 197C, officially for a refueling, but that shutdown happened shortly after confirmatinn that the facdity sits wthin hundreds of feet of three carthquake fault 'The leakage problern is not a decomnissioning cost. I consider et an operating He added the utdity has ' severely underettimated the cost of decommissioning.,

decommissioning cost instead of an operatin By treatingexpense.,'

it as a Welch sai transition charge * headroom * for stranded ass.t cost, however, the utility avoids dipping into its competition etcess money gathered from ratepayers to pay off its stranded aasets until 2002:

leak corras out of operating expenses, then there vall be 59.5 million less to apply to stranded assets 19.5 mdlion less that PC&E's shareholders might ru:elv If the CPUC a were established.pproves PC&E's access to decoi.wmissioning funds,it wdl be the first time since the funds

'

For each utility's reactors, a sinksg fund is set up, aside from other utility revenu That fund has been invested for about 15 years and is oupposed to have enough money in it by 2015 2020 to

' cover the' costs of safe burial of the reactors and all their radioactive parts. However, the technical difficulties of decommissioning have yet to be solved. No long ter.m waste disposal site has even begun to be prepare Humboldt's radioac".tve parts have been decaying on site for 21

.

most<adioactive elements to completely decay p.A. Savage), years it will take about 250,000 years for th

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Humboldt Beacon June 19,1997

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PG&E Takes Steps To Stop Watgx Leak. AtJur_eka Plant .

By JONATHAN JEISEL convinced the company to start inside of the plant,whichis kept at a Beacon Staff Writer repair ,

s1fght vacuum. .

EUREKA- Pacific' Gas and Ango said a svajor increase in De move is designed to save Electric Co. is busy with repain on the rate of inflow could produce PO&E money as it conducts future its Humboldt Bay power plant andis pools of standing water within the repain and eventually disassembles making plans to dismantle its tower,- reactor casing that would be costly the nuclear portion of the plant, tog vent strek sometime next spring. to dispose o since the filtration system , won't

' Alec Ango,PO&E public affairs He also said if the leak's flow have to be continuously' update representative, said the cornpany happened to revene directions, it ne reactoris expecte'd to be keptin started workin January to curbleak; could contaminate groundwater, its cunent " mothballed" state until ing groundwater in the underground The aqutfers under the plant are disassembled in 2015.' ' f b concrete casing that houses the used by PG&E forindustrialpurpos- 'if approved by' the Cabf$rnia.-

es. Ango wasn1 awan of any o6er Me WUdes Codu% M as to rational 19 , h t

"'""' $4.5 million project is expected, to was closed because it is built on an .

Crews are currently working to begin next April, and will be funded ear 6 quake faul gain access to the leak, which will from $156 million PG&E set aside ,

Arago said brackish groundwater has leaked for some time through a pr uably be seabd with a high tech to dismantle the plan .

seam in the outer layer of the dou. grout. Total cost of the tepairs is Arago,said the stack will proba ;

ble walled casing. Engineers antici, estimated at about $9.5 millio . bly be taken down by crane, a pated such minor leaks when PG&E also plans to dismantle process that lasts about three designing the plant and incorporated and replace the curnnt vent. stack month "1bere won't be a spectaculanl

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a drainage system,but an increase in with a modern filtration syste the rate ofleakage over the past year * Ac vent stack filten air from the dynamite explosion," **~-

he said. '

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THURSDAY, June 2G,1997 _

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! Powerplantescapesselloff E PG&E wants to shed more facilities, r

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emitobe sitting ahnost entopof an ,, hf.fy pfg %f y

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f!y David Anderson '

vi n, nm-, vamsant er rthquake fault. "Ihe fuel rods are h.,7", , ,

3Qa 9 ,y [ gr. -;M i,wg.fg -

61 st'11 stored on site, awaiting ewn- * c' 4 runo SAr. MON - 'Ihe ilumboldt tual transportation to an apprured [ [,f*,.M f.' 6 $ .Mk k ' q gb.o Nf j h Day power plant won't gel 'he ax. disposal sit ,

Ns,di@%(tp., ,. hg 'gy.jg'y ' h ht 3G xf -

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nmv or fri the foreseeable futur '* i Arago said the ilumboldt Bay g"..) h:W .j g hg.nih,j{,(i

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Marific Cas and E!cetric Co. this W " ' -

w-ek announted It wt!! se;I four plant is n'so useful to the ccmpany ~

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3_ more power plants, including the as part of tis distribution syste j ,

[p5 g p hf3 torte geothermal cumplex at the stablitzing voltage that comes crer Geysers in I,ake and Sonoma coun-transmission IInes from Reddin j .y jf ,1

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7 ties. In October, the utt11ty an- g-

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nounml plans to sell plants in ized at this end ~ he sai i

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Morm Day. Moss landing. Oakland j W  % $6 aw , %- jy- .

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and San Frandsc Tie plant. whidi uses natmal Detween them. the pbnts to be gas to generate electridty, can also h

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., 2'm$y5.194

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sol.1 repres-r*t 98 percent of the be used as back-up to provide ,

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, W company's fossi!-fud generating c power to IlumboldtCounty custom-i

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acity. InaE emctais safd. Ifum. ers whenererwinterstenns mptme Wm x ,l+,,A %M n7,94 ,

!,widtIbI stheonlyfoss:

! fudplant the 18gh-voltage transmission 1:n-s d " '

fmm the Central Valle $ -l:n ,,

hs k m n Alec Arago sal.I the Ihnnboldt Ilay plant won't --' - ' ' ' ' -  : -- -- 4 In response to restrutturing -

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%% %3 ,,.g go on the block because It's stiU g gg pg needed -and because its atta Utilities Commission. PG&E is in Pacific Gas & Electric Co.'s Humboldt Bay power plant in King

" P"C'" I C "*""5 I"' " ' Salm n, shs twm in a 1996 photo, isn't for sal len4 t e fu s se stb **tical ver monopoly which generate The ccmpanyhas valued the imir

.

transmits and distributes power to Company spokesman Lloyd

[cha ar po sti iltyt one that primarily distributes pcuer Coker said the plant can generate plants at about $750 mil:lon. al-the maclear plant is complefefr de- to retan cusicmer about 1.224 megawatts from wens though its omcials cc icede they mr;ntssioned and cleaned up drined 2 m!Ies under the Mayaca- may twt fetch as much en the open

'Ihe nuclear plant, constructed in .Ihree of the power plants n-wly as M untains Into a natural vel- market. Betwe-n them they have 1968. was closed and mothbaHed listed for sale are fossll-fuel plants canic cauldm G cmpicytes, cfwhich 201 are at 13 years later when it was discer- ' In Antloch, Pittsburg and San Fran- ""'

cisco. But the Geysers comple Coker did not know why PG&E developed in the 1940s and pur- dedded to seH fts geethermal com- 'Ihe company plans to keep most chasedbyPG&EIn 19GO.was oneof p;cx along with its fossli-fuel plants. of !!s hydmelectric plants and !ts the first " alternative energy * pr> IIe said that on!y 14 cf the original controversial D!ablo Canyon nu-jects. It is the largest g-ethermal 24 wens arr st!H pmdudng steam. c! ear plan electrical generator in the worl I _ _ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - --

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CAlJTORNIA ENERGY MARKETS e June 20,1997 e No. 418 e Page 15

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[20] PG&E TRIES TO ACCESS DECOMMISSIONINC FUNDS FOR HUMBOLDT BAY (> rror., ts); .

OnJune 13, Pacdic Cas & Electne proposed tapping into 'not more than $16 million* from decornmissioning funds to repair and upgrade the mothba]!ed Humboldt Bay nuclear plant lacWce ler*er W8 ET. If the plan is approved by the Califomia Pubhc Ut21mes Commitsion, the funds would be spent tte seal water leaks in and out of the reactor containment vessel and to conduct a new radiolopcal stte survey (su CEM No. 416 [14]).

In addition, PC&E would tear doe an existing vent stack and replace it wtth a modem ventilation spterr The 65 MW nuclear plant was shut down in 1976 due to earthquake hazards. Its reactor and spent f remain on ede at the edge of Humboldt Bay, basically under lock and chair) in a mode called SAFESTO No actual decommissioning work has been performed in the intervening 21 year The bulk of the money $9.5 million-would go to plugging the leaky day teeps reactor into thehousin concrete an Currentjy,d steel su rounding the reactor.up to

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The bulk of the money according to the Nudear Regulatory Commission. PC&E maintains I Would go to plugging the but one source who water rendy w onTy rked onseeps the plantin, not back claimed that w out to the bayhen the tide goes ou leaky reactor shell, so does radioactive water. Alec Arago, PC&E spokesperson, admitted that radioactive water pumped from the leaking housing is sent through a canal that is subject to tidal flows. Some water is pumped through the on-site radwaste fac Inty before being released into the bay.

( 'Although the in-leakage does not represent a threat to public health or safety, under worst-case assumptions, it could overtake water removal and processing capabiltty, if the worst case scenano were to were flooded, there would be a significant increase in the total decommissioning cecur, andthethe costs,* noted [ housing)

utJllty in its CPUC notice. According to Arago, the worst case would be that the lea continue and water wuld enter the reactor casing. If so, decommissioning work would be not only radioacthe, but wet, too, Now, Arago said, the infusion of water stays in the sub-floor and is subject to pumping out. According to a two-month old Nuclear Regulatory Commission report, a 9,000 gallon / day leak would take up about two-thirds of the plant's sump pump capacit PC&E maintains there is no danger to the public from the leaky retetor container. According PC&E's em self-monitonng reports, human exposure from the direct and cleaned up leak dscharge--for example of a person who lived near the Bay and ate fish from the Bay-would be 4/10,000ths of a millirem per yea '

The whole plant results in a 0.03 mdlirem addition to the environment per year, according to Arago.The Nr lim #t is 5 millirem per yea "

other o id ut ut(irty did not test for n ano rt &E' ontto ing bou '00013 effluent from the plant. The NRC threshold is 20 picoeuries/miliiter

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avail le en d o decommissioning fund to make sure monev !s issioni g techno og ex ai ent m deco s ing the pla th f p 0 in A A loca safe-energy group, the Redwood Alliance, maintains that faing the leaks near the reactor is an ongoing operation and maintenance problem not a d ng n n. M treated as OW, the costs could come Nt of shareholders' pockets [JA Savage

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. i i HE MIDAS TOUCH F- hi reverse: Instead of the suit, the rags and the water nology does not exist to get them '

E ', gold, ev'erythin' 'oneg , touch on th. e'way,hecome radioac. asfely to a disppsal site,even if one

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y touches turns bordbly . tive. *, .:';,." ., . g/ .', ". .

existed.

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. * letha Nudear janitors have been a ' To no one's surydse, the concrete

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W, That's whathapp'e ns when hwn . plying l grout to Humboldt's leaks .and steel vessel surrounding the re-fers of tudear plants try toilean *:for months.'I'he tido co,mes in actor' started leaking in 1993.- af '

l 'them'up. And' that is ?what's hap. thro, ugh b holes,in the casing, ter 30 years ofbemgiwhar+4ve.

, ' ning up on the besitti . ' W . c, .} p;figWhen'it 'g'oes out, it .

By this timelastyear,it started

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11 redwood enastofHum" = takes radioactivity with. to become a'real problem. PG&E 1 '

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j boldt Cointy, where an' : it.The company expects . maintains that only fodr tan'-tho !

,Jold tudear plant is 14ak. 9 .tbe.leaka to' pe'rsist at sandths of a millirem of radioactiv-l f least . through .this ity are discharged into Humboldt -

Tag 8,000 gallona.of:raq l ldioactive. water per dayJJ _4 ' Tmahth. !.* . Bay, far below the federal limit of

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p ., J. Unlika nicefnudear, 50 millireth peritseyes4.:,. .if. No'stata *

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'hntoHumboldtDay.lj ;? Imagine a typica ni." .% '

PG&E mo'nitors wr. Only instead'of over . $ t .% as built powerplants,Humboldt underground .:or federal e- agents are there hrrow-alls,thisjanitoris coered f %', f ..- right next to Hum. boats with Geiger counters mmMng

. head-to toe in a white nu . , , . _

boldt Bay and right next _ sure PG&E is correct. , * ;; , , .

. clear ' bunny" suit, .outfitr j' . 'to three ' earthquake ..Anothet thing about the Midas .ted with a super-dooper . . n .a t ~ij'La*n- faults. Although. the Touchin 3 reverse -instead'ofmake i

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plant was shut dowb in ing gold, the continued contamh i respirator and s dosage b A 1 P' b

.padge.1magme'thatjani ,l ',.

," 1976"after'13' years of . tion costs money every' time it aq has a standard issue s # - .s .. operation, all the ra- spreads. In this case,.PG&E re-gucket of soapy watar and rags.E .Mi=+4ve partsSe still on sit qu'ested $95mmtem frein rate pay ', -

', YOur hudear janitor pada down There's n6where to put them for 'ers to for thepatchjob.N ,

O PG&E's leaky Humboldt plant .' -

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, and tries to patch.up the. hales in, "gg

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nho e and st.ehdin Jhe reactor with soinething resem-blingswabs

.lhen grout.down Our:nudear then leaky walljanitor ' bk b BQ o 9 te. c. E fywvGR.,

$th rags and' soapy water, then 4 returns to the outsidew' orld. ' N .

gM M'/ .\ . k,*

• . Everything the janitor touched * *

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while demning up has tru ned toxic...

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'Ibe . bunny suit is sealed and ~sent - -

1Washingtin sGta for decontatil- '

?., nation; so tre,the rM The' ws.s water is now radioactive.'It'Is ient through"an on site 'decontamina-

.tiOD. facility.' ,, ., . . ,

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• $Euminerc6ntributsJ.A.Saucie Vis on editorfor California Energy'

' 5farkets

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