IR 05000133/2018003
| ML18291A654 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 10/17/2018 |
| From: | Janine Katanic NRC Region 4 |
| To: | Franke J Pacific Gas & Electric Co |
| References | |
| IR 2018003 | |
| Download: ML18291A654 (14) | |
Text
October 17, 2018 Mr. Jon A. Franke Vice President, Power Generation Pacific Gas and Electric Company P.O. Box 56 Mail Code 104/6 Avila Beach, CA 93424 SUBJECT: HUMBOLDT BAY POWER PLANT INSPECTION REPORT 050-00133/2018-003 This letter refers to the U.S. Nuclear Regulatory Commissions (NRCs) inspection conducted on September 24-26, 2018, at the Humboldt Bay Power Plant, Unit 3 facility, near Eureka, California. The purpose of the inspection was to determine whether decommissioning activities were being conducted safely and in conformance with NRC requirements and the conditions of your license. The NRC inspector discussed the results of the inspection with Bill Barley, Site Closure Manager, and other members of your staff at the conclusion of the onsite inspection on September 26, 2018. The results of the inspection are documented in the enclosure to this letter.
This inspection examined activities conducted under your license as they relate to public health and safety, the common defense and security, and to confirm 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, performance of confirmatory surveys, and interviews with personnel. No violations were identified, and no response to this letter is required.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, 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 NRCs Agencywide Documents Access and Management System (ADAMS) accessible from the NRC Web Site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response, if you choose to provide one, should not include any personal privacy or proprietary information so that it can be made available to the Public without redaction.
Should you have any questions concerning this inspection, please contact Dr. Robert Evans at 817-200-1234, or the undersigned at 817-200-115
Sincerely,
/RA/
Janine F. Katanic, PhD, CHP, Chief Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety Docket No.: 050-00133 License No.: DPR-7 Enclosure: see next page
J. Franke 2 Enclosure:
Inspection Report 050-00133/2018-003 cc w/enclosure:
B. Barley, Pacific Gas and Electric H. Hamzehee, Pacific Gas and Electric J. Post, Pacific Gas and Electric J. Salman, Pacific Gas and Electric P. Soenen, Pacific Gas and Electric G. Perez, California Dept. of Health Services R. Weisenmiller, California Energy Commission Chairman, Humboldt County Board of Supervisors
U.S. NUCLEAR REGULATORY COMMISSION Region IV Docket No.: 050-00133 License No.: DPR-7 Report No.: 050-00133/2018-003 Licensee: Pacific Gas and Electric Co.
Facility: Humboldt Bay Power Plant, Unit 3 Location: 1000 King Salmon Av Eureka, California 95503 Inspection Dates: September 24-26, 2018 Inspector: Robert Evans, PhD, PE, CHP, Senior Health Physicist Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety Approved by: Janine F. Katanic, PhD, CHP, Chief Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety Attachment: Supplemental Inspection Information Enclosure
EXECUTIVE SUMMARY Humboldt Bay Power Plant, Unit 3 NRC Inspection Report 050-00133/2018-003 This U.S. Nuclear Regulatory Commission (NRC) 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 decommissioning activities in accordance with site procedures, license requirements, and applicable NRC regulations.
Decommissioning Performance and Status Review at Permanently Shutdown Reactors The licensee conducted work in accordance with the general instructions provided in the Post-Shutdown Decommissioning Activities Report. The licensee continued to implement a cross-contamination prevention and survey program, as required by the license and site procedures. (Section 1.2)
Self-Assessment, Auditing, and Corrective Action at Permanently Shutdown Reactors The licensee implemented the quality assurance audit and corrective action programs, as required by the Quality Assurance Plan. The licensee self-identified potential weaknesses in its corrective action program and implemented program changes to address these potential weaknesses. (Section 2.2)
Occupational Radiation Exposure The licensee controlled occupational exposures, through secondary surveys and environmental monitoring, to ensure compliance with regulatory requirements. (Section 3.2)
Solid Radioactive Waste Management and Transportation of Radioactive Materials The licensee packaged and shipped radioactive and non-radioactive, but hazardous wastes in accordance with procedural and regulatory requirements. (Section 4.2)
Radioactive Waste Treatment, and Effluent and Environmental Monitoring The licensee implemented the effluent and environmental monitoring programs, as required by the license. The licensee reported the results to the NRC, as required by the Quality Assurance Plan. The licensee concluded that site activities had a negligible impact on the environment and members of the public in 2017. (Section 5.2)
Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors The licensee was conducting final status surveys in accordance with the License Termination Plan and procedural requirements. The inspector conducted three confirmatory surveys. None of the areas exhibited elevated radiological measurements, suggesting that the areas had been effectively remediated by the licensee. (Section 6.2)
Report Details Site Status On July 2, 1976, Humboldt Bay Power Plant, Unit 3, was shut down for an annual refueling outage and to conduct seismic modifications. In June 1983, the Pacific Gas & Electric Company (the licensee) announced its intention to decommission the Unit 3 facility. On July 16, 1985, the NRC issued Amendment 19 to the Unit 3 license to change the status of the license to possess-but-not-operate, and the plant was placed into a SAFSTOR status. The transfer of spent fuel from the spent fuel pool to the onsite independent spent fuel storage installation was completed in December 2008, and the decontamination and dismantlement phase of Humboldt Bay Power Plant, Unit 3, commenced at that time.
At the time of the inspection, the decommissioning activities in progress included management of contaminated soils, removal of underground utilities and commodities, transportation of contaminated and non-contaminated soils and waste material, and final status surveys of land areas that had been remediated. Other work in progress included construction of roads and parking lots that will remain at the site after decommissioning has been completed, and contouring of the site for drainage reasons. The licensee plans to complete site restoration activities and final status surveys by 2019.
1 Decommissioning Performance and Status Review at Permanently Shutdown Reactors (71801) Inspection Scope The inspector evaluated whether the licensee was conducting decommissioning activities in accordance with procedural, license, and regulatory requirements. Observations and Findings The post-shutdown decommissioning activities report dated July 19, 2013, provides a general description of the planned decommissioning activities (Agencywide Documents Access and Management System [ADAMS] Accession ML13213A160). The inspector conducted site tours to observe work in progress. The observed work included soil excavation and contouring, surveys of soil for reuse onsite, and shipment of waste materia In general, the licensee was nearing completion of the onsite work. All structures that were planned to be demolished have been demolished, and all remaining structures will be repurposed at the conclusion of the decommissioning project. Soil was being excavated, screened for radioactive and non-radioactive hazards, and staged for disposal or reuse, as appropriate. The inspector observed radioactive material being packaged and shipped for offsite disposal. The inspector also observed how the licensee was radiologically surveying soils for reuse at the site. In summary, the licensee was conducting work as described in the post-shutdown decommissioning activities repor The inspector reviewed the licensees control of areas that had been final status surveyed in the past. The licensee is required by the license and site procedures to control areas and work activities to prevent cross contamination of areas previously
surveyed. The licensee developed and implemented a cross contamination prevention program. In accordance with procedural requirements, the licensee conducted limited verification surveys on a periodic basis. The inspector reviewed the licensees recent survey results for the new power generation area, an activity specifically mentioned in the license. The licensees survey results indicate that the new power generation area had not been cross-contaminated from decommissioning activities being conducted in the vicinity of the released area.
1.3 Conclusions The licensee conducted work in accordance with the general instructions provided in the post-shutdown decommissioning activities report. The licensee continued to implement a cross-contamination prevention and survey program as required by the license and site procedures.
2 Self-Assessment, Auditing, and Corrective Action at Permanently Shutdown Reactors (40801)
2.1 Inspection Scope The purpose of this portion of the inspection was to evaluate the effectiveness of licensee controls to identify, resolve, and prevent problems that may degrade safety and the quality of decommissioning. In particular, the inspector reviewed the licensees implementation of its corrective action and quality assurance audit programs.
2.2 Observations and Findings Although there are no longer any safety-related systems or components at the Unit 3 site, several program areas continue to be controlled by the quality assurance progra These program areas include the radiation protection, final status survey, recordkeeping, and corrective action program The requirements for the corrective action program and quality assurance audits are provided in the quality assurance plan (QAP). The most recent QAP was submitted to the NRC by letter dated February 23, 2018 (ADAMS Accession ML18066A137).
Section 16 of the QAP discusses the corrective action program, while Section 18 discusses the audit program. Details about the programs were provided in implementing procedures. In summary, the licensee had implemented its corrective action and quality assurance audit programs in accordance with QAP requirement At the time of the inspection, the licensee was required to conduct two routine audit The first audit included the radiological protection, offsite dose calculation manual (ODCM), and radiological environmental monitoring programs. The second audit included the implementation of the license termination plan and final status survey program. The audits are required to be conducted every 2 years. The first audit was conducted in 2016, and the next audit was expected to begin in the near future. The second audit was conducted in 2017 and was reviewed during the inspectio The license termination plan and final status survey audit was found to be a comprehensive review of the two program areas. The audit identified three deficiencies, two weaknesses, three recommendations, and five observations. The inspector
reviewed each of the audit findings in detail. The licensee issued SAPNs (SAPNs are the name of the licensees computerized corrective action program documents) for each finding. One finding involved a perceived observation of complacency of the licensees onsite staff due to the reduction in radiological hazards at the site. The licensee took corrective actions, including training, to help prevent actual or perceived complacency in the future. A second audit finding indicated that the licensee was not effectively using its corrective action program to identify negative trends in certain program area The inspector noted that licensee took corrective actions to improve its implementation of the corrective action program as identified in the quality assurance audit. One corrective action included assignment of an individual to the position of corrective action program champion. This individual was responsible, in part, for ensuring that the program was properly implemented and to produce quarterly reports of the status of the corrective action progra The inspector reviewed portions of the licensees corrective action program including several higher severity level SAPNs. The inspector also reviewed the most recent quarterly report and discussed the report with the corrective action program champio The quarterly report included safety issues that had been identified in the previous quarter and status of higher severity level SAPNs. The inspector concluded that the licensee implemented improvements in the corrective action program that should address the concerns referenced in the quality assurance audit.
2.3 Conclusions The licensee implemented the quality assurance audit and corrective action programs, as required by the QAP. The licensee self-identified potential weaknesses in its corrective action program and implemented program changes to address these potential weaknesses.
3 Occupational Radiation Exposure (83750)
3.1 Inspection Scope The inspector reviewed the licensees occupational radiation exposure program for compliance with regulatory requirements. The review included recent changes to the program, control of external exposures, control of internal exposures, control of contamination, and implementation of the as low as reasonably achievable program.
3.2 Observations and Findings In 2015, the licensee conducted a study to determine if occupational monitoring was required to comply with regulatory requirements. The study was conducted, in part, because decommissioning efforts had removed most of the radioactive material from the site. The study concluded that occupational monitoring was not required due to the low radioactive source term that was present at the site. However, the licensee continued to conduct radiological surveys and contamination monitoring to verify that site conditions had not changed. By letter dated March 27, 2018 (ADAMS Accession ML18087A435),
the licensee notified the NRC that individual monitoring was not required, and that no worker was assigned an occupational exposure for 201 At the time of the inspection, the licensee continued to conduct surveys and sampling to verify that occupational monitoring was not required. These surveys included weekly area gamma radiation surveys and contamination control surveys. A recent survey documented that the highest ambient gamma radiation survey measurement was approximately 0.08 millirem per hour on contact with a radioactive water holding tan Although this area was posted as a radioactive materials area, the survey result was well below the regulatory limit of 5.0 millirem per hour for posting as a radiation area. The licensee also used the results of the environmental monitoring program to help ensure that area radiation exposures are not trending upward In addition to ambient gamma radiation surveys, the licensee conducted surveys for contamination on equipment, staff, and building surfaces. The inspector reviewed a selected sample of surveys performed in 2018 and concluded that the records indicated that no contamination control issues were present at the sit The inspector reviewed one radioactive contamination event that occurred in February 2018. During final stages of the caisson removal work, four occupational workers were potentially exposed to airborne contamination. The workers provided bioassay samples to determine if they had experienced an uptake of radioactive material. One worker tested positive for strontium-90 at a level just above the minimum detectable activity of the sampling equipment. The licensees staff investigated and documented the potential dose to the worker. Based on the sample result and time of intake, the licensee concluded that the internal exposure for the worker was less than 1 millirem with a regulatory limit of 5,000 millirem per year. Since the sample result was well below 10 percent of the regulatory limit, the worker was not formally assigned a dose for that incident.
3.3 Conclusions The licensee controlled occupational exposures, through secondary surveys and environmental monitoring, to ensure compliance with regulatory requirements.
4 Solid Radioactive Waste Management and Transportation of Radioactive Materials (86750)
4.1 Inspection Scope The inspector reviewed whether the licensee properly processed, packaged, stored, and shipped radioactive material in accordance with procedural and regulatory requirement The program areas specifically reviewed included the licensees implementation of the radioactive waste management program and shipping of wastes for disposal.
4.2 Observations and Findings The inspector reviewed procedures and records to ascertain whether the licensee was loading and shipping radioactive material in accordance with regulatory requirement The inspector also interviewed the individuals who implemented the shipping program at the site. In summary, the inspector concluded that the licensee was implementing the transportation program in accordance with regulatory requirement The licensee conducted three basic types of shipmentsradioactive, non-radioactive but hazardous, and non-hazardous shipments. The inspector reviewed a representative record of each type of shipment. The inspector compared the completed shipment records to the requirements specified in the respective licensee procedures. The inspector concluded that transportation activities were being implemented in accordance with the instructions provided in the applicable procedures.
The licensee provided a summary of the waste shipments to the NRC in the annual radioactive effluent release report for each calendar year. The 2017 report was submitted to the NRC by letter dated March 27, 2018 (ADAMS Accession ML18087A429). The licensee provided a summary of the different types of shipments completed in 2017 in the report.
The licensee made two radioactive waste shipments in 2018. One shipment went to a licensed disposal facility in Texas, and the second shipment went to a licensed disposal facility in Utah. The completed packages included verification of the waste profile, shipping paper, driver instructions, package and vehicle surveys, and verification of receipt of shipments at the respective disposal sites. The shipment records were thorough and complete. The licensees staff used checklists to help ensure that the records were complete.
The inspector reviewed one representative exempt quantity shipment that contained low-level concentrations of radioactive material. This shipment was sent to a disposal site in Idaho that is authorized to accept these types of shipments. The NRC has placed a total limit on the quantities of waste material that can be disposed at the Idaho facility (see ADAMS Accession ML102870344, ML120620450, and ML12299A056). The licensee continued to maintain records documenting the total amount of material shipped under each of the three exemption requests.
At the time of the inspection, the licensee had not exceeded any of the quantity limitations specified in the three exemption requests. The licensee had reached the 88 percent limit for the third exemption for solid, non-aqueous wastes. However, the licensees staff indicated that most of these shipments had been completed, and it was unlikely that the licensee would need to ask the NRC for an increase in this exemption limit.
The inspector briefly reviewed how the licensee designated a waste stream and how it determined radioactive concentrations in the waste stream. Waste stream profiling and the associated concentrations are used to determine the disposal site and manifested quantities of radioactive materials being shipped. For example, miscellaneous yard wastes were categorized as a waste stream for disposal as exempt quantity material.
The licensee conducted this particular evaluation in 2014. The evaluation included a limit on the radioactive exposure rate for this waste stream. The inspector confirmed that the exposure rate limits had been incorporated into the implementing procedure. As long as the material in the package (yard wastes, in this example) met the physical description and the material exposure rates met the analyzed limitations, then the material could be packaged, manifested, and shipped as exempt quantity wastes to the Idaho facility for disposal. In summary, the licensees records indicate that the site staff was loading and shipping exempt quantity wastes in accordance with the limitations set forth in the original evaluation .3 Conclusions The licensee packaged and shipped radioactive and non-radioactive, but hazardous wastes, in accordance with procedural and regulatory requirements.
5 Radioactive Waste Treatment, and Effluent and Environmental Monitoring (84750)
5.1 Inspection Scope The objectives of this portion of the inspection were to ensure that the licensee effectively controlled, monitored, and quantified releases of radioactive material in liquid, gaseous, and particulate forms to the environment. The NRC review included changes to the ODCM, dose commitments to the public, and implementation of the radiological environmental monitoring program.
5.2 Observations and Findings The technical specifications, an appendix to the license states, in part, that the requirements for the ODCM, effluent control, and environmental monitoring programs are provided in the QAP. The inspector reviewed the QAP, ODCM, annual radiological environmental monitoring report for 2017, and annual radioactive effluent release report for 2017 during the inspection (ADAMS Accessions ML18066A137, ML17089A747, ML17089A750, ML18123A361, and ML18087A429). In summary, the licensee implemented effluent and environmental monitoring programs in accordance with the QAP, and public doses were well below the regulatory limit At the time of the inspection, there were no effluent releases in progress. With regards to liquid effluents, the licensee permanently suspended liquid releases in 2013 when the liquid radwaste system was taken out of service. Since 2013, liquid radioactive wastes have been shipped offsite for processing and disposal as necessar The potential for noble gas and iodine releases was eliminated when the spent fuel was placed into sealed canisters by 2008. In addition, the licensee discontinued stack monitoring for particulate releases when the stack was taken out of service in 2015; although, the licensee committed to continue to monitor releases from portable ventilation systems, if used during decommissioning. According to the licensees records, there were no ventilation system releases in 201 The environmental monitoring program included air particulate and external radiation exposure monitoring. The licensee maintained five air sampling stations, one offsite and four onsite. As allowed by the QAP, the licensee recently discontinued one onsite station due to ongoing decommissioning activities. At the time of the inspection, the licensee continued to maintain four onsite stations in the four compass directions. The licensees records indicate that all onsite air sample results were comparable to background level In addition to air particulate sampling, the licensee continued to monitor ambient gamma radiation levels using thermoluminescent dosimeters. At the time of the inspection, the licensee had 16 onsite dosimeters, 4 offsite dosimeters, and 1 control dosimeter. The highest ambient gamma radiation dose was measured at an onsite location situated near the north-northeastern fence line of the property. This location averaged 15.9 millirem
per quarter with a background average of 12.6 millirem per quarter. According to the licensees representative, the elevated measurements at this location were most likely caused by naturally occurring radioactive material emanating from nearby erosion protection rock The licensee discontinued groundwater sampling in May 2017. The licensee previously implemented the program on a voluntary basis. Sampling was conducted primarily to measure the tritium (hydrogen-3) concentrations in groundwater. Sample results for tritium in 2017 were below the minimum detectable activities of the sampling equipmen The licensee assessed doses to members of the public on an annual basis. The licensees assessment for 2017 concluded that public doses were less than 1 millirem per year, well below the regulatory limit of 100 millirem per year. The licensee concluded that site decommissioning activities did not have measurable radiological impacts on the environment or members of the public.
5.3 Conclusions The licensee implemented the effluent and environmental monitoring programs as required by the license. The licensee reported the results to the NRC, as required by the QAP. The licensee concluded that site activities had a negligible impact on the environment and members of the public in 2017.
6 Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors (83801)
6.1 Inspection Scope The inspector verified if radiological measurements, surveys, and documentation of surveys were being conducted in accordance with the license termination plan and site procedures. The inspection included observation of remedial action support, final status, in-process, and confirmatory surveys.
6.2 Observations and Findings The inspector observed the licensees performance of various types of surveys, and the inspector conducted three confirmatory surveys concurrently with the licensees survey In summary, the licensees representatives were conducting the surveys in accordance with written instructions that were consistent with the guidance provided in the license termination pla Section 5 of the license termination plan provides the requirements for final status surveys (ADAMS Accession ML18066A137). During the inspection, the licensee conducted a final status survey in two survey units located adjacent to the new power generation facilities. The inspector reviewed the final status survey planning worksheets which provided instructions for how to conduct the surveys. The inspector concluded that the worksheet instructions were consistent with license termination plan requirement The final status surveys consisted of ambient gamma radiation scans and soil samplin The scans were conducted to identify any area that exhibited count rates greater than
background. The licensees representatives conducted the scan surveys in accordance with the instructions provided in the worksheets. Soil samples were also collected by the licensee to compare radioactive material concentrations in the samples to the release criteria. The licensee also collected duplicate samples for quality control purposes. The licensee plans to formally submit the results of these final status surveys to the NRC at a later dat The inspector conducted a confirmatory scan survey in conjunction with the licensees final status surveys. The inspectors survey instrumentation was similar to the equipment used by the licensee. The inspector used a Ludlum Model 18 survey meter with Ludlum Model 44-10 probe (NRC 012778 with a calibration due date of July 17, 2019). No radioactivity above background levels was identified by either the inspector or the licensees representatives during the confirmatory scan or final status survey The inspector conducted a second confirmatory survey in an area that had been excavated and was about to be backfilled near the main entrance to the site. This survey was a verification survey, to confirm that the area could be backfilled. The third survey conducted by the licensee, and confirmed by the inspector, was a turnover survey that was performed in the eastern portion of the site property. This survey was conducted to ensure that the area was ready for a final status survey. Similar to the first survey, the inspector and licensees representatives did not identify any area with count rate measurements above background levels during the verification and turnover surveys.
6.3 Conclusions The licensee was conducting final status surveys in accordance with the license termination plan and procedural requirements. The inspector conducted three confirmatory surveys. None of the areas exhibited elevated radiological measurements, suggesting that the areas had been effectively remediated by the licensee.
7 Exit Meeting Summary The inspector presented the inspection results to the licensees representatives at the conclusion of the onsite inspection on September 26, 2018. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was provided to the inspector during the inspectio SUPPLEMENTAL INSPECTION INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee B. Barley, Site Closure Manager D. Gilson, Project Manger B. Lopez, Licensing G. Madison, Site Closure Final Status Survey Engineering Supervisor W. Parish, Radiation Protection Engineer K. Rowberry, Site Closure J. Salmon, Deputy Director INSPECTION PROCEDURES (IPs) USED IP 71801 Decommissioning Performance and Status Review at Permanently Shutdown Reactors IP 40801 Self-Assessment, Auditing, and Corrective Action at Permanently Shutdown Reactors IP 83750 Occupational Radiation Exposure IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring IP 83801 Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors ITEMS OPENED, CLOSED AND DISCUSSED Opened None Closed None Discussed None LIST OF ACRONYMS USED ADAMS Agencywide Documents Access and Management System IP Inspection Procedure NRC U.S. Nuclear Regulatory Commission ODCM Offsite Dose Calculation Manual QAP Quality Assurance Plan Attachment
ML18291A654 SUNSI Review ADAMS: Non-Publicly Available Non-Sensitive Keyword:
By: RJE Yes No Publicly Available Sensitive NRC-002 OFFICE DNMS:FCDB C:FCDB NAME RJEvans JFKatanic SIGNATURE /RA/ /RA/
DATE 10/17/18 10/17/18