IR 05000133/2010002

IR 05000133-10-002, Pacific Gas and Electric Company, Humboldt Bay Power Plant, Dated 04/13/2010

ML101030137
Person / Time
Site:	Humboldt Bay
Issue date:	04/13/2010
From:	Spitzberg D NRC/RGN-IV/DNMS/RSFSB
To:	Conway J Pacific Gas & Electric Co
References
IR-10-002
Download: ML101030137 (17)

Text

April 13, 2010 Mr. John Senior Vice President-Energy Supply & Chief Nuclear Officer Pacific Gas and Electric Company P.O. Box 3 Mail Code 104/6/601 Avila Beach, California 93424

SUBJECT: NRC INSPECTION REPORT 050-00133/10-002

Dear Mr. Conway:

This refers to the inspection conducted on March 15-18, 2010, at the Humboldt Bay Power Plant, Unit 3 facility, in Eureka, California. The enclosed report presents the results of this inspection. This inspection was an examination of activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel. In summary, the inspector determined that you were conducting decommissioning activities in accordance with license and regulatory 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 you choose to provide one, 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's 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. Robert Evans, Senior Health Physicist, at (817) 860-8234 or the undersigned at (817) 860-8191.

Sincerely,

/RA/ D. Blair Spitzberg, PhD, Chief Repository & Spent Fuel Safety Branch Docket: 050-00133 License: DPR-7

Enclosure:

NRC Inspection Report 050-00133/10-002 UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION IV612 EAST LAMAR BLVD, SUITE 400ARLINGTON, TEXAS 76011-4125 Pacific Gas and Electric Company - 2 -

REGION IV Docket: 050-00133 License: DPR-7 Report: 050-00133/10-002 Licensee: Pacific Gas and Electric Company

Facility: Humboldt Bay Power Plant, Unit 3 Location: 1000 King Salmon Avenue Eureka, California 95503 Dates: March 15-18, 2010

Inspector: Robert Evans, PE, CHP, Senior Health Physicist Repository & Spent Fuel Safety Branch Accompanied By: John Hickman, Project Manager Decommissioning and Uranium Recovery Licensing Directorate Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs

Approved By: D. Blair Spitzberg, PhD, Chief Repository & Spent Fuel Safety Branch Attachment: Supplemental Inspection Information

ENCLOSURE - 2 -EXECUTIVE SUMMARY Humboldt Bay Power Plant, Unit 3 NRC Inspection Report 050-00133/10-002 This inspection was a routine, announced inspection of decommissioning activities being conducted at the Humboldt Bay Power Plant, Unit 3 facility. In summary, the licensee was conducting site activities in compliance with regulatory and license requirements.

Organization, Management, and Cost Controls

• The organizational structure was in agreement with quality assurance (QA) Plan requirements. A sufficient number of staff members were available for the decommissioning activities in progress. Routine program reviews were being conducted as required by the license. The licensee implemented a work control process that may help reduce worker errors in the field (Section 1).

Safety Reviews, Design Changes, and Modifications

• The licensee's safety review program was conducted in compliance with 10 CFR 50.59 requirements (Section 2).

Self Assessment, Auditing, and Corrective Action

• The licensee implemented the QA and corrective action programs in accordance with QA Plan requirements (Section 3).

Decommissioning Performance and Status Review

• The licensee conducted decommissioning activities in accordance with license and regulatory requirements. Radioactive postings and boundaries were maintained in accordance with regulatory requirements. Radiological characterization work was conducted in the spent fuel pool in accordance with procedure requirements. The licensee discovered minute but measurable amounts of radioactivity in the plant ventilation effluent, and the licensee took corrective actions to address the release of this material (Section 4).

• The licensee's response to the January 2010 earthquake was comprehensive. The earthquake did not cause significant damage to the facility. The licensee plans to investigate the source of a leak originating in an inaccessible pipe tunnel later this year (Section 4).

Occupational Radiation Exposure

• The licensee implemented an occupational radiation exposure program that was in compliance with regulatory requirements. No individual exceeded the regulatory limit for total effective dose equivalent exposures during calendar year 2009 (Section 5).

ENCLOSURE - 3 -Solid Radioactive Waste Management and Transportation of Radioactive Materials

• The licensee conducted radwaste handling and transportation activities in accordance with procedure and regulatory requirements (Section 6).

ENCLOSURE - 4 -Report Details Summary of Plant Status-Unit 3 During the inspection, the Humboldt Bay Power Plant, Unit 3, was being decommissioned by the licensee in accordance with commitments made in its Post-Shutdown Decommissioning Activities Report dated June 30, 2009. The licensee commenced with decommissioning during May 2009.

Since the last inspection, the licensee removed the spent fuel racks from the spent fuel pool (SFP), and packaged the racks for shipment to an out-of-state disposal facility. The packaged racks were temporarily stored in the restricted area yard during the inspection. The licensee also finished cutting and sealing the penetrations into the reactor pressure vessel to allow for flooding of the vessel. At the time of this inspection, the licensee finished flooding the reactor pressure vessel with demineralized water for the first time in approximately 25 years. The vessel was flooded primarily to shield personnel from radiation originating from within the vessel.

Following vessel fill, the licensee plans to commence with safety valve and main steam valve removal from the vessel head area. Next, the licensee plans to remove and dispose of the reactor pressure vessel head. The licensee then plans to conduct reactor pressure vessel characterization work, in part, to determine how to remove and dispose of the vessel.

Other work in progress during the inspection included removal of plant equipment from the main condenser area, reactor feed pump room, and pipe tunnel. The licensee removed and packaged the lube oil cooler during the inspection. The licensee also continued to prepare for future cutting of alpha contaminated piping in the reactor feed pump room. In other areas, the licensee continued to construct the new count room building, access control point, and respirator decontamination facility.

The licensee continued to construct a new natural-gas fired power generation plant on site property. Following the construction of the new power plant, the licensee plans to commence with the decommissioning of Units 1 and 2 by removing all of the hazardous materials from the structures. The shutdown and decommissioning of Units 1 and 2 are scheduled to commence as early as September 2010.

The licensee plans to submit an exemption request to the NRC for alternate disposal of the building rubble and soil collected during the demolition of Units 1 and 2, and a small portion of Unit 3. If approved by the NRC, the licensee would be allowed to dispose of this waste material at a facility authorized to accept hazardous material with low levels of radioactive contamination.

1 Organization, Management, and Cost Controls (36801)

1.1 Inspection Scope

The inspector reviewed management organization and controls to ensure that the licensee was maintaining effective oversight of decommissioning activities.

ENCLOSURE - 5 -1.2 Observations and Findings The organizational requirements are specified in the Humboldt Bay Quality Assurance (QA) Plan for the Unit 3 facility. The inspector reviewed the licensee's organizational structure for compliance with QA Plan requirements. The licensee had staffed all management positions, and the licensee appeared to have sufficient staff for all work activities in progress. In summary, the organization in place at the time of the inspection complied with QA Plan requirements.

Since the previous inspection, the licensee made two changes to the organization. The licensee reassigned a new individual to the position of site services manager. Also, the licensee reassigned responsibility for oversight of the site training department from the site services manager to the engineering manager.

The QA Plan stipulates that the licensee maintain a Plant Staff Review Committee (PSRC). The PSRC is responsible for reviewing operating and maintenance activities, proposed changes and tests to the facility, changes in procedures, and any other matter that may have a bearing on the facility. The PSRC is required to meet at least quarterly and at other times at the discretion of the chairman. The inspector reviewed the licensee's implementation of the PSRC. The committee met numerous times during 2009-2010, and the meetings were a combination of regular and special sessions. The records indicate that the committee reviewed and approved procedures, technical basis documents, and one non-conformance report. The inspector concluded that the licensee's PSRC functioned in accordance with QA Plan requirements.

The inspector reviewed portions of the licensee's work control processes to ensure that work was being conducted in accordance with site procedures. Administrative Procedure HBAP C-45, Work Control Process, delineates the work control process for Unit 3 decommissioning. As part of the process, the licensee created Request for Information (RFI) forms. The RFI process allows workers to request clarification or additional information associated with work orders. In recent months, the licensee promoted the RFI process as a mechanism for workers to use when encountering an unknown situation in the field. For example, a RFI form would be used if the workers encountered an electrical wire and were unsure if the wire was energized or de-energized. The RFI process was supposed to help reduce the number of human errors that occur in the field.

The inspector reviewed the RFI process including trending of RFIs. The records indicate that the RFI process was extensively used during January-February 2010, but it was not clear if this trend was continuing. Also, the licensee's representatives planned to review the topics described in the RFIs to determine if any trends were evident, but this review was incomplete at the end of the onsite inspection.

1.3 Conclusions The organizational structure was in agreement with QA Plan requirements. A sufficient number of staff members were available for the decommissioning activities in progress. Routine program reviews were being conducted as required by the license. The licensee implemented a work control process that may help reduce worker errors in the field.

ENCLOSURE - 6 -2 Safety Reviews, Design Changes, and Modifications (37801)

2.1 Inspection Scope The inspector conducted reviews of the licensee's design change program to ensure compliance with the requirements of 10 CFR 50.59.

2.2 Observations and Findings The licensee conducted its last 10 CFR 50.59 safety evaluation prior to the previous inspection. This safety evaluation eliminated the SFP rupture scenario from the Defueled Safety Analysis Report. Instead of reviewing safety evaluations, the inspector selectively reviewed several changes that had been screened by the licensee for a full safety evaluation. The inspector concluded that the licensee had correctly screened these change documents against the criteria established in 10 CFR 50.59.

The inspector reviewed the design change requests and the temporary procedure that the licensee developed for installation and operation of the reactor pressure vessel level transmitters and level indicators. As part of the decommissioning process, the licensee has to radiologically characterize the reactor vessel. To conduct this work, the licensee elected to fill the vessel with water to control airborne radioactivity and to provide radiological shielding. Prior to filling the vessel, the licensee modified a number of penetrations in the vessel, installed two sets of level transmitters and level indicators, and installed a drywell leak detection system. These design changes were screened by the licensee for compliance with 10 CFR 50.59 requirements, but a full review was not necessary because the filling of the vessel with water did not impact the licensing and design bases of the facility.

Following installation of the level instrumentation and modification of the penetrations, the licensee began filling the vessel with demineralized water in a controlled manner. The filling was conducted in accordance with instructions provided in a temporary procedure. The inspector observed the installed level equipment and observed the licensee's filling operations. The installed equipment appeared to be well constructed.

The licensee conducted the filling operations in accordance with procedure requirements. The licensee's penetration modifications appeared to be effective because no leaks developed during the filling process. At the end of the inspection period, the vessel had been filled to the desired level. The inspector concluded that the design and implementation of the level indicators, field modification of reactor vessel penetrations, and fill of the vessel were activities that were well planned, controlled, and implemented by the licensee.

2.3 Conclusions The licensee's safety review program was conducted in compliance with 10 CFR 50.59 requirements.

ENCLOSURE - 7 -3 Self Assessment, Auditing, and Corrective Action (40801)

3.1 Inspection Scope The inspector evaluated the effectiveness of the licensee in identifying, resolving, and preventing issues that could degrade safety or the quality of decommissioning.

3.2 Observations and Findings The inspector reviewed the licensee's implementation of its QA program requirements. The QA program requirements are specified in the Humboldt Bay QA Plan. The QA plan specified the program areas that were required to be audited. The licensee maintained an audit matrix to track the audits and the required audit frequencies. The audit schedule was maintained by QA staff at Diablo Canyon Power Plant. The inspector reviewed the audit schedule and discussed the schedule with a representative of the QA staff. The inspector confirmed that all audits had been completed or were scheduled to be completed in a timely manner.

The inspector reviewed three audits including the emergency preparedness, fire protection, and effluent/environmental program audits. The audits were determined to be comprehensive. No significant audit findings were identified by the QA auditors. Problems and deficiencies identified by the auditors were included in the licensee's corrective action program for resolution. Audits scheduled for 2010 include the training, license compliance, corrective action, radiation protection, and security programs. These completed audits will be reviewed during a future inspection.

The QA Plan requires the licensee to establish a program for corrective action and nonconformance control. The inspector also reviewed the licensee's most recent list of SAP Notifications, the licensee's problem reporting system. The inspector concluded that the licensee staff continued to document potential problems and proposed corrective actions. The licensee also continued to monitor the implementation of these corrective actions. The licensee's SAP notification process continues to be an effective mechanism for self-identification and correction of potential problems.

3.3 Conclusions The licensee implemented the QA and corrective action programs in accordance with QA Plan requirements.

4 Decommissioning Performance and Status Review (71801)

4.1 Inspection Scope The inspector evaluated whether the licensee and its contracted workforce were conducting decommissioning activities in accordance with license and regulatory requirements.

ENCLOSURE - 8 -4.2 Observations and Findings a. Site Tours The inspector toured the radiologically restricted areas of the facility. Radiological postings were clearly visible, and postings met the requirements of 10 CFR Part 20.

Housekeeping was being controlled in all areas. During site tours, the inspector conducted radiological surveys to verify the accuracy of radiation area postings using a Ludlum Model 2401-EC2 survey meter (NRC No. 016294G, calibrated due date of 01/04/11). The inspector did not identify any radiation area that was incorrectly posted by the licensee.

During the inspection, the licensee was conducting radiological characterizations of the contents being stored in the SFP. The characterization work was conducted, in part, to determine the waste classifications of the material. The radioactive materials in the pool included a vacuum cleaner, used filters, start-up source rack, interim storage container, and miscellaneous tools, straps, poles, and hooks. The licensee's representatives were conducting the characterization surveys underwater with extended detectors and video monitoring equipment. The inspector noted that the licensee was conducting and documenting the work results in accordance with site instructions.

The inspector reviewed the licensee's recent discovery of minute amounts of americium-241 in the plant exhaust. The licensee discharges ventilation air from the radiologically restricted areas through filters prior to release to the environment. The licensee discovered measurable quantities of americium-241 in the November 2009 plant stack composite sample. Although the radioactivity was detectable, the concentration of the radioactivity was well below the regulatory limit for effluent releases. With a measured concentration of 3.83 E-17 microcuries of americium-241 per milliliter of air, this sample result was well below the regulatory effluent concentration limit of 2E-14 microcuries per milliliter. The licensee's representatives noted that americium-241 was not detected in the December 2009 and January 2010 samples. The licensee's representatives believe that the radioactivity in the sample may have been the result of air leakage around the seals of the discharge filter banks. In response, the licensee replaced and functionally tested the filters for leaks. The licensee plans to resolve this potential issue prior to first cut of an alpha contaminated pipe, currently scheduled for mid-April 2010.

b. Follow Up of Licensee's Response to January 2010 Earthquake

On January 9, 2010, a 6.5 magnitude earthquake occurred about 26 miles southwest of the site. At that time, the licensee conducted a number of responses including site and building inspections. During this inspection, the inspector conducted a follow up review of the earthquake's impact on the plant. The inspector reviewed the licensee's corrective action reports written in response to the earthquake and interviewed staff members who were responsible for implementing the corrective actions.

Immediately following the earthquake, the licensee conducted engineering inspections of site structures. Minor structural cracks were observed, but none of the cracks were considered to be significant from an engineering standpoint. The most significant damage was the failure of an expansion joint in a pipe tunnel. This resulted in an increase in groundwater inflow into the tunnel. The expansion joint and the accessible ENCLOSURE - 9 -wall cracks were repaired with foaming grout material. These repairs reduced the groundwater in-leakage to a manageable level.

The licensee's representatives pointed out that pile driving activities occurred during the construction of the new generation facility during 2009, and these construction activities may have been the cause of some of the tunnel wall cracks. The earthquake may have then exacerbated these cracks and leaks.

The licensee discovered strontium-90 contamination in some of the water collected from the offgas/liquid radwaste piping tunnel. This tunnel was the location of a resin spill in the past, and some of the groundwater in-leakage may be coming into contact with residual contamination from the spill. This contaminated liquid is being collected by the licensee through the turbine building drain tank, and this fluid is being processed and sampled prior to release to the environment. Because the offgas/liquid radwaste pipe tunnel is not accessible, the licensee plans to excavate an access point to the tunnel this summer. This access point will be used to allow the licensee to visually inspect the tunnel. Once the licensee has inspected the tunnel, the licensee will formulate the corrective actions needed to repair the leaks originating in this tunnel. The licensee also procured additional equipment for use as needed to process the potentially contaminated liquid. At the time of this inspection, the licensee had not placed this equipment into service because the permanent plant equipment was capable of processing the volume of inflow.

4.3 Conclusions The licensee conducted decommissioning activities in accordance with license and regulatory requirements. Radioactive postings and boundaries were maintained in accordance with regulatory requirements. Radiological characterization work was conducted in the spent fuel pool in accordance with procedure requirements. The licensee discovered minute but measurable amounts of radioactivity in the plant ventilation effluent, and the licensee took corrective actions to address the release of this material.

The licensee's response to the January 2010 earthquake was comprehensive. The earthquake did not cause significant damage to the facility. The licensee plans to investigate the source of a leak originating in an inaccessible pipe tunnel later this year.

5 Occupational Radiation Exposure (83750)

5.1 Inspection Scope The inspector reviewed occupational radiation exposures to verify compliance with 10 CFR Part 20 requirements.

5.2 Observations and Findings The licensee continued to maintain a program for monitoring occupational exposures to radiation. The licensee monitored and maintained records for exposures to both external and internal exposures. The inspector reviewed the occupational exposure records for calendar year 2009. During 2009, approximately 350 individuals were monitored by the licensee.

ENCLOSURE - 10 - Thermoluminescent dosimeters (TLDs) were issued to individuals to measure external gamma doses. The TLDs were exchanged on a quarterly basis. The licensee's records indicate that the combined total effective dose equivalent exposures were about 0.623 person-rems during 2009 for all individuals with a measurable gamma radiation dose. The highest dose to an individual, a radiation protection technician, was 0.052 rems with a regulatory limit of 5 rems per year. Occupational exposures were well below the regulatory limit during 2009.

Internal doses were typically based on air sample, bioassay, and whole body count results. During 2009, no individual was assigned an internal dose because there were no statistically positive lapel air sample results. In addition, there were no positive in-vivo sample results based on whole-body counts and bioassay sample results.

The total exposure for 2009 was down from 2008, when the combined external dose was 2.05 person-rems. During 2008, the work projects with the highest dose potential included cleaning of the SFP, offloading of the fuel, and shipping of radioactive resins. The licensee recently estimated the potential occupational exposures for 2010. The estimated total dose was 16.7 person-rems. The project that had the potential for the most doses during 2010 was work associated with the characterization and removal of the reactor pressure vessel.

5.3 Conclusions The licensee implemented an occupational radiation exposure program that was in compliance with regulatory requirements. No individual exceeded the regulatory limit for total effective dose equivalent exposures during calendar year 2009.

6 Solid Radioactive Waste Management and Transportation of Radioactive Materials (86750) 6.1 Inspection Scope The inspector reviewed the licensee's programs for characterizing and shipping the radioactive wastes that will be generated during site decommissioning.

6.2 Observations and Findings The inspector reviewed the licensee's programs for handling, packaging, and shipping radioactive wastes. The inspector observed the licensee loading an intermodal with radwaste, storing intermodals on site property, and preparing an intermodal for shipment to an out-of-state disposal site. The inspector concluded that the work was conducted in accordance with site procedures and with an emphasis on industrial and radiation safety.

Shipping papers are required by U.S. Department of Transportation regulations (49 CFR 172, Subpart C). The inspector reviewed one representative shipping paper for an intermodal that was shipped offsite during the inspection. This intermodal contained soil in bulk form. The inspector compared the classification of the shipment, and the completed waste manifest, to procedure requirements. The inspector concluded that the material in the intermodal had been properly classified for disposal, the intermodal had ENCLOSURE - 11 -been properly prepared for shipment, and the shipping manifest had been completed in accordance with procedure requirements.

6.3 Conclusions The licensee conducted radwaste handling and transportation activities in accordance with procedure and regulatory requirements.

7 Exit Meeting The inspector reviewed the scope and findings of the inspection during an exit meeting that was conducted at the conclusion of the onsite inspection on March 18, 2010. The licensee did not identify as proprietary any information provided to, or reviewed, by the inspector.

ATTACHMENT SUPPLEMENTAL INSPECTION INFORMATION PARTIAL LIST OF PERSONS CONTACTED J. Albers, Radiation Protection Manager R. Arroyo, Site Services Manager B. Barley, Radiation Protection Planning P. Barringer, Radwaste Shipping M. Celletti, Training Coordinator J. Chadwick, Radiation Protection Operations Supervisor A. Cordone, Decommissioning Projects Superintendent J. Davis, Radiation Protection Engineer J. Griffin, Mechanical Engineering Supervisor D. Malone, Regulatory Engineer D. Morrow, Electrical Supervisor L. Pulley, Deputy Decommissioning Manager K. Rod, Decommissioning Manager P. Roller, Director and Nuclear Plant Manager S. Schlerf, Radiation Protection Foreman B. Sicotte, Quality Control Supervisor M. Smith, Engineering Manager D. Sokolsky, Licensing Supervisor R. Sorensen, Emergency Planning M. Stein, Radiation Protection Supervisor L. Whitchurch, Civil Engineering Supervisor INSPECTION PROCEDURES USED IP 36801 Organization, Management, and Cost Controls IP 37801 Safety Reviews, Design Changes, and Modifications IP 40801 Self Assessment, Auditing, and Corrective Action IP 71801 Decommissioning Performance and Status Review IP 83750 Occupational Radiation Exposure IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed None Discussed None ATTACHMENT - 2 -LIST OF ACRONYMS CFR Code of Federal Regulations IP NRC Inspection Procedure PSRC Plant Staff Review Committee QA quality assurance RFI Request for Information form SFP spent fuel pool TLD thermoluminescent dosimeters