IR 05000133/2006003

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IR 05000133-06-003; Pacific Gas and Electric Company; 9/25-29/2006; Humboldt Bay Power Plant Unit 3 Facility
ML062900198
Person / Time
Site: Humboldt Bay
Issue date: 10/16/2006
From: Spitzberg D
NRC/RGN-IV/DNMS/FCDB
To: Keenan J
Pacific Gas & Electric Co
References
IR-06-003
Download: ML062900198 (16)


Text

October 16, 2006Mr. John Senior Vice President - Generation and Chief Nuclear Officer Pacific Gas and Electric Company P.O. Box 770000, Mail Code B32 San Francisco, California 94177-0001 SUBJECT:NRC INSPECTION REPORT 050-00133/06-003

Dear Mr. Keenan:

An NRC inspection was conducted on September 25-29, 2006, at your Humboldt Bay PowerPlant Unit 3 facility. This inspection was an examination of activities conducted under yourlicense as they relate to safety and compliance of the Commission's rules and regulations and with the conditions of your license. Within these areas, the inspection included reviews of your organization and management; safety reviews, design changes and modifications; spent fuel pool safety; decommissioning performance and status; and solid radioactive waste management and transportation of radioactive materials. On September 29, 2006, at the conclusion of the site visit, an exit briefing was conducted with Mr. Terry Nelson, Plant Manager, and other members of your staff. The enclosed report presents the scope and results of that inspection. The inspection determined that you were conducting decommissioning activities in compliance with regulatory and license requirements. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response (if any) will be made available electronically for public inspectionin the NRC Public Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/Adams.html. To the extent possible,your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. Should you have any questions concerning this inspection, please contact the undersigned at(817) 860-8191 or Emilio M. Garcia at (530) 756-3910.

Sincerely,

/RA J. Vincent Everett for/D. Blair Spitzberg, Ph.D., ChiefFuel Cycle and Decommissioning BranchDocket No.: 050-00133 License No.: DPR-7

Enclosure:

NRC Inspection Report 050-00133/06-003 Pacific Gas and Electric Company - 2 -

REGION IV Docket No.:050-00133License No.:DPR-7 Report No.:050-00133/06-003 Licensee:Pacific Gas and Electric Company (PG&E)

Facility:Humboldt Bay Power Plant (HBPP), Unit 3Location:1000 King Salmon AvenueEureka, California 95503Dates:September 25-29, 2006 Inspectors:Emilio M. Garcia, Health PhysicistRobert J. Evans, P.E., C.H.P., Senior Health Physicist Approved By:D. Blair Spitzberg, Ph.D., ChiefFuel Cycle and Decommissioning BranchAttachments:Supplemental Inspection Information ADAMS Entry:IR 05000133-06-03, on 09/25-29/06; Pacific Gas & Electric Co.;Humboldt Bay, Unit 3. No violations.

-2-EXECUTIVE SUMMARYHumboldt Bay Power Plant, Unit 3NRC Inspection Report 050-00133/06-003The Humboldt Bay Power Plant (HBPP), Unit 3 was shutdown in 1976. The facility has been ina SAFSTOR status since shutdown with minimal decommissioning activity. Organization, Management and Cost Controls*The licensee had sufficient staff to conduct the work in progress, including an amplenumber of certified fuel handlers. The onsite and offsite review committees were functioning in accordance with quality assurance program requirements. The licensee had established a nuclear safety concerns program in accordance with site procedures to give employees an alternate opportunity to report safety concerns. The licensee conducted an emergency response drill that met the intent of the Emergency Plan(Section 1).Safety Reviews, Design Changes, and Modification*The licensee's safety review program was conducted in compliance with 10 CFR 50.59requirements. Plus, the licensee had established and implemented a non-conformance program that was in compliance with Quality Assurance Plan requirements (Section 2).Spent Fuel Pool Safety*The licensee was maintaining the spent fuel pool water level and water chemistry inaccordance with Technical Specifications requirements and Defueled Safety Analysis Report commitments (Sections 3).Decommissioning Performance and Status Review*Radiological conditions of the facility were properly posted. Housekeeping and facilityconditions were effectively controlled (Sections 4).Solid Radwaste Management & Transportation of Radioactive Materials*The licensee had implemented and maintained a transportation program for radioactivematerials and radioactive waste in accordance with NRC and U.S. Department ofTransportation regulations (Section 5).

-3-Report DetailsSummary of Plant StatusHumboldt Bay Power Plant, Unit 3, is currently in decommissioning SAFSTOR status. Unit 3received an operating license from the Atomic Energy Commission on August 28, 1962. On July 2, 1976, Unit 3 was shutdown for annual refueling and seismic modifications. This work was suspended in December 1980 and in June 1983, then PG&E announced its intention to decommission the unit. Unit 3 has been essentially in SAFSTOR since July 1985. On July 19, 1988, NRC approved the licensee's SAFSTOR plan and amended the license to apossess-but-not-operate status. The license will expire on November 9, 2015. The facility hasundergone minimal decommissioning activity since shutdown. 1.0Organization, Management, and Cost Controls (36801)

1.1Inspection ScopeThe inspectors reviewed site staffing, onsite and offsite safety review committees,nuclear safety concerns program, and an Emergency Plan drill for compliance withregulatory requirements, site procedures, and licensee commitments.1.2Observations and Findings a.Site OrganizationTechnical Specifications 5.2.1 provides the requirements for the onsite and offsiteorganizations necessary for the safe storage of irradiated fuel. The onsite nuclear organization chart was provided in site procedure HBAP A-1, HBPP Organization and Staff Qualifications," Appendix 6.4, Revision 25. The inspectors compared the actualstructure in place at the time of the inspection to the procedure requirements. All staff positions had been filled, except one. The licensee recently created the position ofdecommissioning project manager, and the licensee plans to fill this position in the nearfuture. Also, the licensee plans to establish the position of Unit 3 manager to reduce the workload of the current Unit 3 supervisor who was responsible for both operations and maintenance work. In summary, the inspectors concluded that the licensee had sufficient staff for the work in progress.Section 5.2.2 of Technical Specifications states that at least one certified fuel handlershall be onsite when fuel is in the spent fuel pool (SFP). The inspectors interviewed the Unit 3 supervisor who stated that the licensee had 19 certified fuel handlers, including 14 in operations, four in management, and one certified training coordinator. In summary, the licensee had sufficient staff to ensure compliance with Technical Specifications requirements for availability of certified fuel handlers. b.Onsite and Offfsite Review CommitteesThe Quality Assurance Plan, Revision 19, provides the requirements for the Plant SafetyReview Committee (PSRC) and the Nuclear Safety Oversight Committee (NSOC). The-4-inspectors reviewed the implementation of the committees to ensure compliance withquality assurance program requirements. Further, the inspectors attended several PSRC meetings that were held during the onsite inspection.The PSRC was the onsite group that reviewed proposed changes, tests andexperiments, plant modifications, procedure revisions, and other issues having nuclear safety significance. During 2006, the PSRC met about 60 times including routine and special meetings. The PSRC meeting minutes were reviewed. Minutes documented that the quorum requirements had been met and provided a list of all subjects reviewed.

The committee reviewed and approved, as appropriate, proposed procedure changes, temporary procedures, plant modifications, negative trends, and non-conformances.

Reasons were documented when proposed changes or procedures were rejected by the committee.The NSOC provided high level review and oversight of site activities including thePSRC. The NSOC was required to meet at least twice per year. The only site person that was a member of this committee was the plant manager. The committee met once in April 2006 and was scheduled to meet again in November 2006. The minutes for the April 2006 meeting were reviewed. A quorum was present, and the committee reviewed relevant issues. c.Nuclear Safety Concerns ProgramThe licensee had established a nuclear safety concerns program to provide employeeswith an alternate opportunity to have concerns impartially and independently examined.

The inspectors interviewed a program representative which included an overview of the program. The Unit 3 Employee Concerns Program was shared with the Diablo Canyon power plant.Program requirements were described in implementing procedure OM3-ID3, "EmployeeConcerns Program," Revision 10. Employees could submit concerns via U.S. Postal Service mail, electronic mail, or telephone hot line. The licensee provided a local contact at the site for consultation. Reminders about the Employee Concerns Program were included in annual general employee training, new employee training, site posters, and brochures that were available onsite. d.Emergency Plan DrillSection 8.1.3 of the Emergency Plan specifies that periodic drills are to be conducted onvarious aspects of the plan to assure that personnel retain familiarity with the plan andto improve response actions when applicable. The Emergency Plan required one announced and one unannounced drill per year.During the inspection, the licensee conducted its annual announced drill. The drillconsisted of a combination accountability drill and medical emergency response. Thelicensee simulated the injury of a contaminated person to test the response capabilitiesof both onsite and offsite personnel. The drill included a test of the emergency sirenand personnel accountability. After the completion of the drill, the licensee conducted-5-debrief sessions to assess the strengths and weaknesses of the drill. The licenseeconcluded that the drill met Emergency Plan requirements as the annual announcedemergency drill. The licensee plans to conduct the unannounced drill prior to the end ofthe calender year.The inspectors reviewed the Emergency Plan, observed portions of the drill while inprogress, and attended the licensee's drill assessment meetings. The inspectorsagreed that the drill met the requirements specified in the Emergency Plan for anannounced drill. 1.3ConclusionsThe licensee had sufficient staff to conduct the work in progress, including an amplenumber of certified fuel handlers. The onsite and offsite review committees were functioning in accordance with quality assurance program requirements. The licensee had established a nuclear safety concerns program in accordance with site procedures to give employees an alternate opportunity to report safety concerns. The licensee conducted an emergency response drill that met the intent of the Emergency Plan.2.0Safety Reviews, Design Changes, and Modifications (37801)

2.1Inspection ScopeThe inspectors conducted reviews of the licensee's design change and nonconformanceprograms to ensure compliance with the requirements of 10 CFR 50.59 and Quality Assurance Plan requirements. 2.2Observations and Findings a.Design Change ProcessThe inspectors reviewed selected design change packages to ascertain whether thechanges included a safety review or safety screening and adequate explanation of the change being proposed. The inspectors reviewed four design change notices related to the permanent plant SFP demineralizer and the new in-pool demineralizer. Each package included a safety screen that included consideration of the requirements of 10 CFR 50.59. Other attributes considered included impacts on decommissioning and whether changes were required to be implemented in licensing basis documents, site procedures, and site drawings. All safety screens were complete. None of the changes involved a full safety evaluation. Further, the design change notices provided sufficient detail to explain what was being changed.The inspectors attended several PSRC meetings during the inspection. The PSRCreviewed several proposed procedure and design changes. One design change request being considered involved the removal of the new fuel inspection stand from the Refueling Building floor. The removal of this item was necessary to clear the area for future decommissioning activities. The proposed equipment removal authorization-6-included a safety review. The removal activity was subsequently approved by thePSRC. b.Nonconformance ReportsSection 3.1.4 of the Quality Assurance Plan states that measures shall be establishedfor documenting, reviewing, and dispositioning of quality problems and non-conformances. The four non-conformance reports (NCRs) for 2006 were reviewedduring the inspection. The first NCR involved the licensee's failure to immediately recognize an increase in theSFP loss rate because of limitations with the instrumentation used to monitor pool level.

The cause of the increased leak rate was subsequently determined to be a mis-positioned valve. The second NCR involved the discovery of a significant increase inthe liquid radwaste holding tank radioactivity level. The cause of the increased radioactivity was identified as in-leakage of contamination into the tank from spilled resinthat has since been cleaned up. The third NCR involved late reporting and inventory ofspecial nuclear material during 2003-2006. Finally, the fourth NCR involved theidentification of four surveillances that were conducted after the end of the respectivedue dates. The inspectors reviewed each of these licensee-identified incidents in detail andconcluded that none resulted in actual safety consequences or releases of radioactive material above regulatory limits. Immediate and longer term corrective actions were proposed in each situation to prevent recurrences. In summary, the licensee was identifying and correcting conditions adverse to quality.2.3ConclusionsThe licensee's safety review program was conducted in compliance with 10 CFR 50.59requirements. Plus, the licensee had established and implemented a non-conformance program that was in compliance with Quality Assurance Plan requirements.3.0Spent Fuel Pool Safety (60801)

3.1Inspection ScopeThe inspectors reviewed the licensee's control of the SFP to ensure compliance withTechnical Specifications requirements and Defueled Safety Analysis Report (DSAR)

commitments. 3.2Observations and FindingsThe inspectors conducted a tour of the SFP area and reviewed plant records to ensurethe safe storage of the fuel and other irradiated items in the pool. Technical Specifications 3.1.1 states that the SFP water level shall be at an elevation of greaterthan 10.5 feet. At the time of the inspection, the water level was 11.02 feet. The-7-inspectors also confirmed that the low water level alarm was set at 10.67 feet asrequired by the DSAR.Technical Specifications 3.1.3 states that the SFP liner water level shall be at anelevation less than +9 inches (0.75 feet). The liner water level was -0.2 feet during the inspection. The inspectors also confirmed that the licensee was monitoring both SFP level and liner water level at the frequencies established in Technical Specifications surveillance requirements.Section 2.3.1.1 of the DSAR states that two sources of makeup water will be maintainedfor the SFP. The inspectors interviewed operations staff personnel and determined that the two waters sources were the demineralized water storage tank and fire water. The DSAR specifies that a minimum of 2,000 gallons shall be maintained in the demineralized water storage tank. At the time of the inspection, the tank contained over4,000 gallons. The fire water system was available for emergency supply of water.Table 5.2 of the DSAR provides the limits for SFP water chemistry and radioactivitylevels. Details of this requirement were documented in site procedure STP 3.6.5,

"Monthly Spent Fuel Pool Water Quality Check," Revision 44. The pool water was routinely sampled for three chemical constituents; pH, conductivity and cesium-137 activity. The inspectors reviewed the plant records for March 2006 through September 2006. The licensee was collecting pool samples on a monthly frequency as required by the DSAR and was analyzing the samples for the required chemical constituents. Since March 2006, all parameters remained within DSAR limits.In recent months, the licensee experienced problems with the in-plant SFPdemineralizer. The licensee experienced a failure of an outlet line which prevented routine sluicing (removal of resin from) the permanent plant demineralizer. The licensee converted an underwater vacuum device into an underwater demineralizer to supplement the permanent plant SFP demineralizer. During the inspection, the licenseecontinued to make repairs and modifications to return the permanent plant demineralizer back to service.Recently, the licensee commenced with a plan to remove irradiated and unirradiatedhardware from the SFP. The licensee wanted to remove all unnecessary components from the pool to provide room for future fuel handling operations and to ship the material offsite prior to closure of an out-of-state disposal site. The licensee recently conducted radiological surveys of the energy absorber in preparation for removal from the pool.

The licensee identified elevated exposure rate readings during its survey. As part of the investigation process, the licensee used an underwater video camera to view the area.

The licensee observed several items that included identifiable and unidentifiable metal objects. The licensee elected to move the items to a temporary storage container in the SFP to continue with the timely removal of the energy absorber from the pool. The licensee will investigate these suspect components at a later date to ascertain theidentities of the items.3.3Conclusions-8-The licensee was maintaining the SFP water level and water chemistry in accordancewith Technical Specifications requirements and Defueled Safety Analysis Report commitments.4.0Decommissioning Performance and Status Review (IP 71801)4.1 Inspection ScopeInspectors conducted tours of the site to evaluate whether the facility conditions werebeing effectively controlled during SAFSTOR. 4.2Observations and FindingsThe inspectors toured the fuel handling building, the Unit 3 control room, and otherareas of the facility. Radiological postings were easily visible and met the requirementsof 10 CFR Part 20. Housekeeping and facility conditions were effectively controlled. Most of the areas in the facility were free of radiological contamination and wereaccessible without the need of protective clothing. No safety concerns were observed during the tours. The control room indicators associated with monitoring spent fuel pool level and spent fuel pool liner level were confirmed to be functional.The licensee had installed a new decontamination facility inside the fuel handlingbuilding. The fabrication of this facility was described in Design Change Notice (DCN)number HB3-EM-600. This facility was intended to accommodate the decontaminationof equipment and components during the removal of waste materials from the spent fuel pool in preparation for the packaging of fuel for removal to the independent spent fuel storage installation that is to be built. The facility consists of a structure that can beenclosed. It includes a ventilation system, and access to the plant demineralized water,electrical and service air systems. The facility had been completed and was operationalduring this inspection.The inspectors observed the preparation and movement of a resin vessel from thedecontamination facility to the "new fuel" storage vault. The movement was conductedsafely and without incident. Appropriate radiation protection practices were used by the workers involved. Members of the licensee's management observed the movement.The inspectors conducted confirmatory radiation surveys using Ludlum Model 2401-ECsurvey instrument, NRC property number 21176G, due for calibration on August 4,2007. The inspectors' survey results were comparable to those performed by the licensee.4.3ConclusionsRadiological conditions of the facility were properly posted. Housekeeping and facilityconditions were effectively controlled.

-9-5.0Solid Radioactive Waste Management and Transportation (86750)

5.1Inspection ScopeThe inspectors reviewed the licensee's solid radwaste management and transportation of radioactive materials program to ensure compliance with NRC and U.S. Departmentof Transportation (DOT) regulations.5.2Observations and Findings a.Audits and AssessmentsThe inspectors interviewed cognizant personnel and reviewed selected documents todetermine if any audits or assessments had been conducted of the solid radwaste management and transportation of radioactive materials program. The licensee had not conducted any audits of this area since this area was last inspected in September 2005.

The next biannual audit of this area was schedule to begin on October 9, 2006, and the audit had been announced by the Quality Verification group to the site management.The inspectors reviewed the report titled "Readiness Review for Shipment ofRadioactive Waste to Barnwell Disposal Facility" dated September 22, 2006. Thisassessment was performed by a consultant with expertise in radioactive materials transportation and radioactive waste disposal requirements. This assessment identified changes that were needed to be made to six licensee procedures for the classification and transportation for disposal of Class B and Class C waste. The licensee initiated SAP Notifications (problem reports) to address the assessment recommendations. b.ChangesThere had been no significant changes in the licensee's organization, personnel,facilities, equipment, or procedures affecting the solid radwaste management andtransportation of radioactive materials program since this area was last inspected September 12-14, 2005. A Radiation Control Standard and two Radiation ControlProcedures related to the solid radwaste management and transportation of radioactive materials program had received their biannual PSRC review, but no standard nor procedure had been revised. c.ShipmentsRecords indicated that 18 shipments of radioactive material had been completedbetween January 1, 2006 and September 29, 2006. Three records were selected and reviewed by the inspectors. These were for radioactive materials shipments (RMS)06-008, RMS06-013, and RMS06-017. RMS06-008 was a metal analyzer shipped as special form solid; RMS06-013 and RMS 6-017 were shipped as an excepted packages limited quantity of material. The records documented compliance with the applicable requirements of Title 49 of the Code of Federal Regulation. The emergency response telephone number listed on the shipping paper was confirmed as a telephone number staffed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. Documents that required shipper certification-10-were signed by a licensee representative. Training records of the individuals whosigned or otherwise performed functions related to the transport of hazardous material were reviewed. The individuals involved with these shipments had received appropriate training as required by 49 CFR 172, Subpart H.The Senior Radiation Protection Engineer stated that the licensee had not received anynotices of non-compliance from DOT or other competent state authorities. The licensee maintained printed copies NRC and DOT regulations and had copies of the licenses ofthe designated recipients. 5.3ConclusionsThe licensee had implemented and maintained a transportation program for radioactivematerials and radioactive waste in accordance with NRC and DOT regulations.6.0Exit MeetingOn September 29, 2006, at the conclusion of the site visit, the inspectors presented tothe plant manager and other licensee staff members, the preliminary results on areas inspected. The licensee did not identify as proprietary any information provided to, or reviewed by, the inspectors.

ATTACHMENTSUPPLEMENTAL INSPECTION INFORMATIONPARTIAL LIST OF PERSONS CONTACTEDJ. Albers, Radiation Protection ManagerM. Antony, Decontamination Technician J. Brimble, Production Supervisor - Fossil J. Chadwick, Senior Radiation Protection Engineer J. Crow, Training Coordinator J. Davis, Radiation Protection Engineer Z. Easley, Security Supervisor J. Galle, Senior Design Engineer M. Grossman, Unit 3 Supervisor V. Jensen, Quality Control Supervisor G. Mason, Quality Assurance Supervisor T. Nelson, Plant Manager - Nuclear J. Rasmussen, Certified Fuel Handler S. Schlerf, Radiation Protection Foreman M. Smith, Engineering Manager D. Sokolsky, Licensing Supervisor R. Sorensen, Programs Coordinator R. Willis, Plant Manager - Fossil INSPECTION PROCEDURES USEDIP 36801Organization, Management and Cost ControlsIP 37801 Safety Reviews, Design Changes, and Modifications IP 60801Spent Fuel Pool Safety IP 71801 Decommissioning Performance and Status Review IP 86750 Solid Radwaste Management & Transportation of Radioactive MaterialsITEMS OPENED, CLOSED, AND DISCUSSED OpenedNoneClosedNone DiscussedNone-2-LIST OF ACRONYMSDCN Design Change NoticeDOT U.S. Department of Transportation DSAR Defueled Safety Analysis Report HBAPHumboldt Bay Administrative Procedure HBPPHumboldt Bay Power Plant IPInspection Procedure NCR Non-Conformance ReportNSOC Nuclear Safety Oversight Committee PG&E Pacific Gas and Electric Company PSRC Plant Safety Review Committee RMS Radioactive Materials Shipment SFP Spent Fuel Pool