ML092230614
| ML092230614 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 08/11/2009 |
| From: | Whitten J NRC/RGN-IV/DNMS/NMSB-B |
| To: | Conway J Pacific Gas & Electric Co |
| References | |
| IR-09-002 | |
| Download: ML092230614 (18) | |
See also: IR 05000133/2009002
Text
August 11, 2009
Mr. John T. Conway
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 050-00133/09-002
Dear Mr. Conway:
This refers to the inspection conducted on July 13-16, 2009, at the Humboldt Bay Power Plant,
Unit 3 facility. This inspection was an examination of activities conducted under your license as
they relate to safety and compliance with the Commissions 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. The enclosed report presents the results of this inspection. In summary, the
inspector determined that you were conducting decommissioning activities in compliance with
regulatory and license requirements.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response, if you choose to provide one, will be made available
electronically for public inspection in the NRC Public Document Room or from the NRCs
document system (ADAMS), accessible from the NRCs 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) 860-8197.
Sincerely,
/RA/
Jack E. Whitten, Chief
Nuclear Materials Safety Branch B
Docket No.: 050-00133
License No.: DPR-7
Enclosure:
NRC Inspection Report 050-00133/09-002
cc w/enclosure:
UNITED STATES
NUCLEAR REGULATORY COMM ISSION
R E GI ON I V
612 EAST LAMAR BLVD, SUITE 400
ARLINGTON, TEXAS 76011-4125
Pacific Gas and Electric Company
- 2 -
James Becker, Site Vice President
and Station Director
Pacific Gas and Electric Company
Diablo Canyon Power Plant
P.O. Box 56
Avila Beach, CA 93424
Jennifer L. Post, Esq.
P.O. Box 7442
San Francisco, CA 94120
Paul Roller, Director and Plant Manager
Humboldt Bay Power Plant, PG&E
1000 King Salmon Avenue
Eureka, CA 95505
Chairman
Humboldt County Board of Supervisors
County Courthouse
825 Fifth Street
Eureka, CA 95501
Law Office of Linda J. Brown, Esq.
300 Drakes Landing Road, Suite 172
Greenbrae, CA 94904
Regional Radiation Representative
U. S. Environmental Protection Agency
Region IX Office
75 Hawthorne Street
San Francisco, CA 94105
Dr. Richard Ferguson, Energy Chair
1100 11th Street, Suite 311
Sacramento, CA 95814
Dr. James F. Davis, State Geologist
Department of Conservation
Division of Mines & Geology
801 K Street MS 12-30
Sacramento, CA 95814-3531
Director, Radiologic Health Branch
State Department of Health Services
P.O. Box 997414 (MS 7610)
Sacramento, CA 95899-7414
Pacific Gas and Electric Company
- 3 -
Director
Energy Facilities Siting Division
Energy Resources Conservation &
Development Commission
1516 9th Street
Sacramento, CA 95814
Gretchen Dumas, Esq.
Public Utilities Commission
of the State of California
5066 State Building
San Francisco, CA 94102
Redwood Alliance
P.O. Box 293
Arcata, CA 95521
James D. Boyd, Commissioner
California Energy Commission
1516 Ninth Street (MS 34)
Sacramento, CA 95814
Pacific Gas and Electric Company
- 4 -
bcc w/enclosure:
A. Howell, D:DNMS
C. Cain, DD:DNMS
J. Whitten, C:DNMS/NMSB-B
S. Williams, OEDO RIV Coordinator
J. Weil, Congressional Affairs Officer
J. Hickman, FSME/DWMEP/DURLD/RDB
R. Evans, NMSB-B
Fee Coordinator, DRMA
DRAFT: S:\\DNMS\\!NMSB-B\\RJE\\HB 050-00133-09-002.doc
FINAL: R:\\_DNMS\\_HB\\2009\\HB 050-00133-09-002.doc
MLxxxxxxxx
OFFICIAL RECORD COPY
T=Telephone E=E-mail F=Fax
Yes No
SUNSI Rev Complete
Reviewer Initials:
RJE
Publicly Avail.
Yes No
Sensitive Value:
RIV:DNMS:NMSB-B
C:NMSB-B
RJEvans
JEWhitten
/RA/
/RA/
08/02/09
08/10/09
ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.:
050-00133
License No.:
Report No.:
050-00133/09-002
Licensee:
Pacific Gas and Electric Company
Facility:
Humboldt Bay Power Plant, Unit 3
Location:
1000 King Salmon Avenue
Eureka, California 95503
Dates:
July 13-16, 2009
Inspector:
Robert Evans, PE, CHP, Senior Health Physicist
Nuclear Materials Safety Branch B
Accompanied By:
Arthur T. Howell III, Director
Division of Nuclear Materials Safety
Approved By:
Jack E. Whitten, Chief
Nuclear Materials Safety Branch B
Attachment:
Supplemental Inspection Information
ENCLOSURE
- 2 -
EXECUTIVE SUMMARY
Humboldt Bay Power Plant, Unit 3
NRC Inspection Report 050-00133/09-002
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 decommissioning activities in compliance with regulatory and license requirements.
Safety Reviews, Design Changes, and Modifications
The licensees safety review program was conducted in compliance with 10 CFR 50.59
requirements (Section 1).
Maintenance and Surveillance
The licensee continued to operate and maintain necessary plant equipment in
accordance with license and procedure requirements (Section 2).
Decommissioning Performance and Status Review
The licensee was conducting decommissioning activities with an emphasis on
radiological safety. Radiation protection controls had been implemented in accordance
with 10 CFR Part 20 requirements (Section 3.2.a).
The licensee conducted an infrequently performed heavy load test in accordance with
work order instructions and with an emphasis on industrial safety (Section 3.2.b).
The license implemented a cross contamination plan in the new fossil generation facility
in accordance with license requirements (Section 3.2.c).
The licensees training program was in agreement with Defueled Safety Analysis Report
requirements, but at the time of the inspection, the licensee was significantly upgrading
the training program to account for the site-specific radiological hazards involving alpha
particulate contamination (Section 3.2.d).
Occupational Radiation Exposure
The licensee implemented an occupational exposure program that effectively monitored
the internal and external doses to radiation. No individual exceeded the regulatory limit
for total effective dose equivalent exposures during calendar year 2008 (Section 4.2.a).
During 2009, the licensee began implementing a program for control of worker
exposures to alpha particulate contamination. This program supports the concept of As
Low As Reasonably Achievable (ALARA) and should help control worker exposures to
licensed material (Section 4).
ENCLOSURE
- 3 -
Radioactive Waste Treatment, and Effluent and Environmental Monitoring
The effluent and environment monitoring programs were in compliance with license
requirements. All required samples had been collected, no sample result exceeded
applicable limits, and no adverse trends were identified. Annual doses to the public
were well below the regulatory limit (Section 5).
Solid Radioactive Waste Management and Transportation of Radioactive Materials
To support the planned decommissioning activities as described in the Post-Shutdown
Decommissioning Activities Report, the licensee developed formal plans for control and
shipping of radioactive wastes. These plans provided detailed reviews and assessments
of work challenges involving radioactive waste disposals (Section 6).
ENCLOSURE
- 4 -
Report Details
Summary of Plant Status
At the time of the inspection, Humboldt Bay Power Plant (HBPP), Unit 3, was being
decommissioned in accordance with commitments specified in the Post-Shutdown
Decommissioning Activities Report (PSDAR) dated June 30, 2009. The licensee commenced
with decommissioning during May 2009. Since May 2009, the licensee has removed the Unit 3
transformers and generator exciter.
In the near future, the licensee plans to remove the generator, seal oil exciter switchgear, and
reactor feed pump room equipment. The licensee may also conduct a radiological survey and
study of the reactor vessel, in part, to ascertain the various options for its removal and disposal.
Also during the inspection, the licensee continued to construct a new power generating plant on
the site property. Following construction of the new power generating plant, the licensee plans
to commence with decommissioning of Units 1 and 2.
1
Safety Reviews, Design Changes, and Modifications (37801)
1.1
Inspection Scope
The inspector conducted reviews of the licensees design change program to ensure
compliance with the requirements of 10 CFR 50.59.
1.2
Observations and Findings
The licensee conducted one 10 CFR 50.59 safety evaluation during 2009. Evaluation
09-01 eliminated a previously analyzed accident scenario. The evaluation deleted the
spent fuel pool (SFP) rupture scenario from the Defueled Safety Analysis Report
(DSAR). Rupture of the SFP was possible based on a seismic event or heavy load drop.
To prevent a heavy load drop accident, plant procedures previously prohibited the
movement of loads greater than 10 tons over the SFP.
The spent fuel was removed from the SFP by December 2008. The licensee conducted
the analysis using the NRC sponsored computer code RESRAD-OFFSITE to verify that
the remaining radioactive material would result in minimal offsite dose in the event of a
rupture of the SFP. Following its approval, this change now allows the licensee to move
heavy loads over the SFP as part of decommissioning activities.
During the inspection, representatives of the licensee stated that several documents
would be updated in the near future including the DSAR. These documents will be
updated, in part, to account for the impacts and hazards of alpha contamination.
1.3
Conclusions
The licensees safety review program was conducted in compliance with 10 CFR 50.59
requirements.
ENCLOSURE
- 5 -
2
Maintenance and Surveillance (62801)
2.1
Inspection Scope
The inspector conducted a review of the equipment that remained in service to support
plant operations, and the inspector observed the performance of selected maintenance
and surveillance activities.
2.2
Observations and Findings
At the time of the inspection, the licensee continued to maintain selected plant systems.
The components that will remain in service included the plant alarm system,
seismograph, stack gas flow monitor, liquid radwaste monitor, radwaste system
components, ventilation equipment, SFP support equipment, instrument air, service air,
and electrical controls. The licensee also continued to operate various in-plant radiation
monitors; however, these monitors are scheduled for permanent removal in the near
future.
The inspector compared operating plant parameters to the procedure limits specified in
the license. All parameters reviewed by the inspector were found to be within the
allowed range. For example, the SFP water level was being maintained in the range
stipulated by plant procedures. In summary, the licensee operated the remaining
equipment in accordance with procedure requirements.
The inspector observed the performance of three maintenance and surveillance tests:
Discharge canal sample station back flush
Stack particulate monitor sampling
Quarterly ventilation system test in the refueling building
In summary, the tests observed by the inspector were completed satisfactorily, and the
operators/technicians appeared knowledgeable of the tasks being conducted.
2.3
Conclusions
The licensee continued to operate and maintain necessary plant equipment in
accordance with and procedure requirements specified in the license.
3
Decommissioning Performance and Status Review (71801)
3.1
Inspection Scope
The inspector evaluated whether the licensee and its contracted workforce were
conducting decommissioning activities in accordance with license and regulatory
requirements.
ENCLOSURE
- 6 -
3.2
Observations and Findings
a.
Site Tours
The inspector toured the fuel handling building, Unit 3 control room, and the other
radiologically restricted areas of the facility. Radiological postings were clearly visible,
and the postings met the requirements of 10 CFR Part 20. Housekeeping was being
controlled in these areas. During the site tours, the inspector conducted radiological
surveys to verify the accuracy of radiation area postings. The inspector did not identify
any radiation area that was incorrectly posted by the licensee.
b.
Heavy Load Lift
During the inspection, the licensee conducted a 125-percent load test of the main 75-ton
crane located within the refueling building. The licensee conducted the test to certify the
75-ton crane to be able to lift a 90-ton load. The load that was lifted during the test
consisted of the shield plug and various free weights. The weight of the lift was
determined by calculation versus direct measurement. A State of California inspector
was present during the load test.
Since this activity was an infrequently performed evolution, a special pre-job briefing was
conducted. The test was then conducted using instructions provided in a work order.
The test included a lift and hold to ensure that the crane breaks worked as designed.
The crane was also moved in each of the four major compass directions, although the
crane movement was constrained by the location of the SFP. In accordance with the
work order, the licensee elected to avoid lifting the heavy load over the SFP.
In summary, the load test was completed in a satisfactory manner, and industrial safety
was evident during all portions of the test. The load test certification has a four year
recertification interval, although annual crane inspections will still be required to keep the
certification current.
c.
Cross-Contamination Plan
License Condition 2.C.4 specifies that a cross-contamination prevention and monitoring
plan be maintained for the location of the new fossil generation facility. The inspector
reviewed the licensees implementation of its cross contamination plan. Site procedure
C-220, Cross Contamination Prevention and Monitoring Plan (Plan), provides the
instructions for the program. The inspector noted that the Plan provided an adequate
overview of the survey program, but the Plan lacked specificity for the implementation of
the cross-contamination prevention and monitoring program. The Plan referenced a
radiation protection procedure for implementation details, but when examined by the
inspector this secondary procedure had not fully incorporated the requirements of the
Plan. During the inspection, a licensee representative stated that the procedure would
be updated in the near future.
Despite the procedure limitation, the licensee conducted an initial radiological survey as
required by the cross contamination plan. The survey was conducted during early July
2009. The radiological survey results obtained indicated that all measurements taken
were indistinguishable from background levels. These survey results suggest that the
licensee has effectively implemented the requirements of the cross contamination plan.
ENCLOSURE
- 7 -
d.
Site Training Program
The inspector reviewed the training program for compliance with 10 CFR 19.12 and
DSAR requirements. Section 4.2.1 of the DSAR provides the training requirements.
The training programs include general employee training, program-specific training, and
respiratory protection training. Details of the training program are included in HBPP
procedures B-2, General Training Requirements for On-Site Personnel, and B-200,
Radiation Protection Training Program. The inspector noted that the licensee was in the
process of significantly updating the training program to account for the radiological
hazards that are present at the site.
At the time of the inspection, general employee and industrial safety training was
provided by the site training department. Function-specific training was provided by the
various departments such as radiation protection, security, and emergency
preparedness departments. General employee training consisted of computer based
training, formal classroom lectures, videotapes, handouts, and an examination.
The radiation protection staff was revising its program-specific training to include the
hazards of alpha contamination. The licensee recently created a new, offsite training
center that included mockups. The mockups will be used to train workers in the
protocols of foaming, cutting, and sealing pipes that may contain alpha contamination.
The mockups included glove boxes and tents that will be used to help control the spread
of contamination.
The training certifications of selected instructors were reviewed. The inspector
determined that the instructors were certified to teach specific classes. The inspector
reviewed selected class records and confirmed that the instructors associated with the
requisite training classes were qualified to teach the classes at the time the class was
given. The licensee maintained an informal list of all classes and the primary instructors
for those classes. Based on a random review, the inspector determined that the
instructors were certified for the courses that were assigned to them.
The inspector reviewed the respiratory protection training program with the applicable
supervisor. The training consisted of computer-based training, a medical physical, and a
fit test. At the time of the inspection, the fit test program was suspended pending receipt
of new masks for fit testing. Previous fit test failures were attributed to improper sealing
of the probe that penetrated the test respirator. The supervisor expects the fit test
program to be full operational prior to commencement of work activities involving alpha
contamination.
The inspector also discussed the applicable respiratory protection procedure with the
radiation protection supervisor. The inspector noted that the procedure had been
updated to account for the new fit testing protocol and special respiratory cleaning and
sampling requirements that must be implemented because of alpha contamination. The
supervisor expected the fit testing procedure to be updated prior to commencement of
work involving alpha contamination. Finally, the licensee plans to construct a new glove
box for cleaning alpha-contaminated respirators, and the licensee plans to provide
special training to workers who will wash and maintain the respirators.
ENCLOSURE
- 8 -
3.3
Conclusions
The licensee was conducting decommissioning activities with an emphasis on
radiological safety. Radiation protection controls had been implemented in accordance
with 10 CFR Part 20 requirements. The licensee conducted an infrequently performed
heavy load test on the 75-ton crane in accordance with work order instructions and with
an emphasis on industrial safety. The license implemented a cross contamination plan
in the new fossil generation facility in accordance with license requirements. The
licensees training program was in agreement with DSAR requirements, but at the time
of the inspection, the licensee was significantly upgrading the training program to
account for the site-specific radiological hazards involving alpha particulate
contamination.
4
Occupational Radiation Exposure (83750)
4.1
Inspection Scope
The inspector reviewed occupational radiation exposures to verify compliance with
10 CFR Part 20 limitations. The inspector also reviewed the implementation of the
licensee=s As Low As Reasonably Achievable (ALARA) program.
4.2
Observations and Findings
a.
Occupational Exposures
Occupational radiation exposures consisted of both external and internal exposures.
The licensee monitored and maintained records of Unit 3 exposures. The inspector
reviewed the occupational exposure records for calendar year 2008. During 2008, 267
thermoluminescent dosimeters were issued to individuals to measure external gamma
doses. The combined total effective dose equivalent for all individuals with a
measurable gamma dose was about 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 highest total effective dose equivalent exposure recorded during 2008 to one
individual was 121 millirems. The highest committed effective dose equivalent exposure
was 27 millirems, a dose that was assigned to two individuals. The regulatory limit for
total effective dose equivalents, a combination of deep dose equivalent and committed
effective dose equivalent, is 5,000 millirems. In summary, site doses during 2008 were
well below the regulatory limit.
To help monitor for internal doses, the licensee conducted bioassay sampling. Bioassay
sampling included entrance, exit, annual, and event-based whole body counting. No
positive whole-body counts were attributed to plant events during 2008, and to the date
of this inspection in 2009.
The inspector reviewed the licensees ALARA program for future work activities. During
interviews, the licensees staff predicted the work activities planned during 2009 that had
the greatest potential for doses to individuals would be the reactor vessel
characterization study (if conducted) and turbine-generator decommissioning. The
licensee estimated that the decommissioning of Unit 3 would result in a total combined
ENCLOSURE
- 9 -
dose of approximately 208 person-rems. The projects with the highest dose potential
include decommissioning of the reactor vessel, SFP, shutdown and cleanup heat
exchangers, and area vaults.
b.
Control of Exposures to Alpha Contamination
The inspector conducted a review of the licensees plans to control occupational
exposures to alpha contamination. The site has a unique radiological hazard due to
alpha particulate contamination. Early fuel failures resulted in the internal contamination
of plant systems with fission products and transuranic radionuclides. The alpha
particulate hazard has increased over time from the decay of plutonium-241, while the
gamma radiation hazards have decreased due to the decay of cobalt-60 and
The licensee plans to commence work that has the potential for exposures to alpha
particulate contamination during October 2009. In response, the licensee developed a
radiation protection procedure for performing and evaluating alpha particulate
contamination postings and surveys. In addition, the procedure provides new controls
for alpha zones. The implementation of this new procedure should help minimize the
potential for worker exposures to alpha contamination.
To help assess the alpha contamination hazard inside of plant piping, the licensee
recently collected a number of coupon samples from various locations including the
turbine and feedwater piping. These samples were submitted to an offsite laboratory for
analysis. The results of these samples will be used, in part, to help characterize the
material for waste disposal and for transportation.
The licensee plans to conduct the cutting of alpha contaminated pipes within glove
boxes or containment tents. The use of glove boxes and tents is expected to reduce the
potential for worker exposures to loose alpha contamination. In addition, the licensee
plans to inject foam material into the pipes to fixate the alpha contamination during
cutting operations. Site workers that enter a contaminated area will be required to wear
lapel air samplers to help the licensee assess worker exposures to radioactive
particulate contamination.
During the inspection, the licensee was in the process of upgrading its training program
for workers that will be potentially exposed to alpha contamination. Industry experts
were being used to upgrade the lesson plan and to teach the class to site workers. All
workers are expected to be retrained prior to commencement of work activities involving
alpha contamination. In addition, the licensee established a mock-up facility to support
training of workers that will be cutting and handling the alpha-contaminated piping.
These training enhancements are expected to help reduce the potential for inhalation or
ingestion of alpha contamination.
Routine whole-body counts are generally ineffective for identifying uptakes of alpha
contamination. The licensee plans to implement an enhanced bioassay program that
will include collection of urine and fecal samples for monitoring of internally deposited
alpha-emitting radionuclides.
The licensee has been procuring new equipment to conduct real-time monitoring of
alpha contamination. The licensee recently placed into service a number of continuous
ENCLOSURE
- 10 -
air monitors that monitor for alpha contamination in addition to beta-gamma
contamination. Further, the licensee plans to install an alpha detecting monitor in the
plant ventilation stack. This monitor was expected to be installed during September
2009, prior to start of decommissioning work involving alpha contamination.
4.3
Conclusions
The licensee implemented an occupational exposure program that effectively monitored
the internal and external doses to radiation. No individual exceeded the regulatory limit
for total effective dose equivalent exposures during calendar year 2008. During 2009,
the licensee began implementing a program for control of worker exposures to alpha
particulate contamination. This program supports the concept of ALARA and should
help control worker exposures to licensed material.
5
Radioactive Waste Treatment, and Effluent and Environmental Monitoring
5.1
Inspection Scope
The inspector reviewed the licensees program to control, monitor, and quantify releases
of radioactive materials to the environment in liquid, gaseous, and particulate forms.
5.2
Observations and Findings
The inspector reviewed the Annual Radioactive Effluent Release Report for 2008 dated
March 26, 2009, and the Annual Radiological Environmental Monitoring Report for 2008
dated April 30, 2009. The inspector compared the results presented in these reports to
the requirements provided in site procedures and the Offsite Dose Calculation Manual.
In summary, all required samples had been collected, and no sample result exceeded a
licensed or regulatory limit. No adverse trends were apparent. The inspector identified
several report errors, and the licensee agreed to update the reports during the next
routine submittals.
The inspector compared the effluent and environmental monitoring results to the public
dose limits specified in 10 CFR 20.1301. In summary, the records indicate that the
public dose limits were not exceeded. The licensees results suggest a maximum public
dose of less than one millirem for 2008 with an annual regulatory limit of 100 millirems.
5.3
Conclusions
The effluent and environment monitoring programs were in compliance with license
requirements. All required samples had been collected, no sample result exceeded
applicable limits, and no adverse trends were identified. Annual doses to the public
were well below the regulatory limit.
6
Solid Radioactive Waste Management and Transportation of Radioactive Materials
(86750)
6.1
Inspection Scope
The inspector reviewed the licensees plans for characterizing and shipping the
radioactive wastes that will be generated during decommissioning.
ENCLOSURE
- 11 -
6.2
Observations and Findings
The PSDAR provides a description and schedule of planned decommissioning activities.
To support decommissioning, the licensee recently developed two plans, a Waste
Management and Disposal Plan and a Transportation Plan. These plans were
developed, in part, to identify the challenges for waste management and to identify
potential options for these challenges. The unique challenges include:
Control of the limited amount of area available for waste handling operations
Establishment of temporary waste storage areas inside and outside of site structures
Control of alpha contaminated material
Removal of contaminated concrete and soils below the water table
Removal of contaminated sediment from the intake and discharge canals
As explained in the PSDAR, the licensee has to decide whether to segment the reactor
pressure vessel and its internals or to dispose of the vessel as a single item.
The licensee estimates that the total volume of contaminated material to be removed
from the site is about 660 thousand cubic feet. The material includes soils, building
rubble, and equipment. The vast majority of the waste material generated will most
likely be classified as Class A wastes for disposal at an out-of-state disposal site. The
wastes will be sorted based on disposal and shipping classification. The licensee also
plans to use radioactive waste processors to consolidate the wastes for disposal. The
use of waste processors may allow the licensee to reduce the volume of wastes
disposed.
In response to the above challenges, the Waste Management and Disposal Plan provide
recommended flow paths for the movement of equipment from the location of
dismantlement to the location of packaging for shipment. This plan also provides a
recommended list of work areas for decommissioning. For example, the main
condenser is considered one such work area. The plan also describes the potential
classification of the waste streams such as Class A bulk wastes and Class A general
wastes.
In general, field crews will remove the equipment from a given area and will relocate the
equipment near the waste containers. The waste handling and packaging crews will
package the waste equipment, and the shipping and transportation crews will ship the
material for disposal. Based on the current work schedule, most wastes will be shipped
during the 2013-2014 time frame. The bulk of the wastes will consist mostly of soils and
building debris.
At the time of the inspection, the licensee was developing a system and area
characterization plan. This plan will help establish the definitions of the various waste
streams and help establish the waste profiles for disposal and shipment. The waste
profiles have to be completed and approved prior to the actual shipment of the waste
materials.
As explained in the Transportation Plan, the licensee estimates that it will ship
approximately 1500 shipments to the out-of-state waste disposal site. Challenges to
ENCLOSURE
- 12 -
transportation include the locations of the staging areas needed to support
decommissioning. Because of the limited amount of space available, the licensee is
expected to tightly control the movement, handling, and storage of waste containers.
A second transportation challenge is the location of the site. The site has limited access
to alternate modes of transportation. There are no rail or barge access points in the
immediate area of the site, so practically all wastes may have to be shipped by truck to
the disposal site. In addition, there are no easy, direct routes to the disposal site.
Further, the licensee will have to comply with length restrictions on the local highways.
At the time of the inspection, the licensee was in the process of adding staff to the
radwaste packaging and transportation groups. Procedures were being upgraded to
provide step-by-step instructions for the work that will be performed. The licensee was
in the process of procuring intermodal containers for shipment of the wastes. The
licensee was also reviewing its options for shipping large components.
The licensee was reviewing its protocols for shipment of other types of waste streams,
including oil and asbestos wastes, for disposal. For example, the licensee was
considering its options for disposal of the fuel oil storage tank, turbine lube oil, and
exciter. These components may be disposed in an alternate manner, as allowed by
10 CFR 20.2002. An alternate disposal methodology was being considered because of
the low radiological hazards associated with these materials.
6.3
Conclusions
To support the planned decommissioning activities as described in the PSDAR, the
licensee developed formal plans for control and shipping of radioactive wastes. These
plans provided detailed reviews and assessments of work challenges involving
radioactive waste disposals.
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 July 16, 2009. 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
B. Barley, Radiation Protection Planning
M. Celletti, Training Coordinator
J. Chadwick, Radiation Protection Engineer
J. Davis, Radiation Protection Engineer
J. Griffin, Engineering Consultant, AM Solutions
L. Hardwick, SAFSTOR Supervisor
L. Pulley, Deputy Decommissioning Manager
K. Rod, Decommissioning Manager
P. Roller, Director and Nuclear Plant Manager
T. Sanders, Site Services Manager
B. Sicotte, Quality Control Supervisor
M. Smith, Engineering Manager
R. Snyder, Radwaste Supervisor
D. Sokolsky, Licensing Supervisor
M. Stein, Radiation Protection Supervisor, Bartlett
B. Stephens, Work Week Manager
INSPECTION PROCEDURES USED
IP 37801 Safety Reviews, Design Changes, and Modifications
IP 62801 Maintenance and Surveillance
IP 71801 Decommissioning Status
IP 83750 Occupational Radiation Exposure
IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring
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
As Low As Reasonably Achievable
CFR
Code of Federal Regulations
Defueled Safety Analysis Report
HBPP
Humboldt Bay Power Plant
IP
Inspection Procedure
Post Shutdown Decommissioning Activities Report
Spent Fuel Pool