IR 05000133/2011007

EA-11-211, IR 05000133-11-007, 07200027-11-001, on 8/1-4/2011, Humboldt Bay Power Plant, NRC Inspection Report

ML11294A516
Person / Time
Site:	Humboldt Bay
Issue date:	10/21/2011
From:	Caniano R Division of Nuclear Materials Safety IV
To:	Conway J Pacific Gas & Electric Co
References
EA-11-211 IR-11-007
Download: ML11294A516 (23)

Text

October 21, 2011

SUBJECT:

NRC INSPECTION REPORT 050-00133/11-007; 072-00027/11-001

Dear Mr. Conway:

This refers to the inspection conducted on August 1-4, 2011, at the Humboldt Bay Power Plant, Unit 3 facility, in Eureka, California. This inspection examined 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 inspector discussed the preliminary inspection findings with members of your staff at the conclusion of the onsite portion of the inspection. A final exit briefing was conducted telephonically with members of your staff on September 23, 2011. The enclosed report presents the results of this inspection.

Based on the results of this inspection, two apparent violations were identified and are being considered for escalated enforcement action in accordance with the NRC Enforcement Policy.

The current Enforcement Policy is included on the NRCs Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The first apparent violation involves your failure to properly transmit safeguards information outside of the authorized place of use or storage in accordance with 10 CFR 73.22. The second apparent violation involves two instances of safeguards information left unattended within your facility, a violation of Condition 12 of NRC License SNM-2514. The licensee communicated the circumstances related to these apparent violations to the NRC on July 20, 2011.

Details about these two apparent violations and your corrective actions, taken in response to your discovery of these issues, are provided in Section 4 of the enclosed inspection report. The circumstances surrounding these apparent violations, the significance of the issues, and the need for lasting and effective corrective action were discussed with members of your staff during the inspection exit meeting on September 23, 2011.

UNITED STATES NUCLEAR REGULATORY COMM ISSION R E GI ON I V 612 EAST LAMAR BLVD, SUITE 400 ARLINGTON, TEXAS 76011-4125

Pacific Gas & Electric Company

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Before the NRC makes its enforcement decision, we are providing you with an opportunity to either respond to the apparent violations addressed in this inspection report within 30 days of the date of this letter or request a Predecisional Enforcement Conference (PEC). If a PEC is held, the NRC will issue a press release to announce the time and date of the conference; however, it will be closed to public observation since security-related information will be discussed. If you decide to participate in a PEC, please contact D. Blair Spitzberg, Ph.D., Chief, Repository and Spent Fuel Safety Branch, at 817-860-8191 within 10 days of the date of this letter. A PEC, if required, should be held within 30 days of the date of this letter.

If you choose to provide a written response, it should be clearly marked as a Response to Apparent Violations in Inspection Report 050-00133/11-007; 072-00027/11-001; EA-11-211 and should include for each apparent violation: (1) the reason for the apparent violation or, if contested, the basis for disputing the apparent violation; (2) the corrective steps that have been taken and the results achieved; (3) the corrective steps that will be taken to avoid further violations; and (4) the date when full compliance will be achieved. Your response may reference or include previously docketed correspondence, if the correspondence adequately addresses the required response. If an adequate response is not received within the time specified or an extension of time has not been granted by the NRC, the NRC will proceed with its enforcement decision or schedule a PEC.

Because these issues involve Safeguards Information, if you choose to respond and Safeguards Information is necessary to provide an acceptable response, your response will not be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS),

accessible from the NRCs Web site at http://www.nrc.gov/reading-rm/adams.html. If Safeguards Information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21. If Security-Related Information is necessary to provide an acceptable response, mark your entire response Security-Related Information in accordance with 10 CFR 2.390(d)(1) and follow the instructions for withholding in 10 CFR 2.390(b)(1). In accordance with 10 CFR 2.390(b)(1)(ii) the NRC is waiving the affidavit requirements of your response.

If you choose to request a PEC, the conference will afford you the opportunity to provide your perspective on the apparent violations and any other information that you believe the NRC should take into consideration before making an enforcement decision. The topics discussed during the conference may include the following: information to determine whether a violation occurred, information to determine the significance of a violation, information related to the identification of a violation, and information related to any corrective actions taken or planned to be taken. In presenting your corrective actions, you should be aware that the promptness and comprehensiveness of your actions will be considered in assessing any civil penalty for the apparent violations.

In addition, please be advised that the number and characterization of apparent violations described in the enclosed inspection report may change as a result of further NRC review. You will be advised by separate correspondence of the results of our deliberations on this matter.

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 and it does not contain Safeguards or security-related information, will be made available electronically for public inspection in the NRC Public Document Room or from ADAMS. Should you choose to provide a response to this

Pacific Gas & Electric Company

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letter, and it contains Safeguards or Security-Related information, it will not be made available electronically for public inspection. To the extent possible, your response should not include any personal privacy, proprietary, security-related, or safeguards information so that it can be made available to the Public without redaction.

If you have any questions concerning this matter, please contact D. Blair Spitzberg, PhD, Chief, of my staff at 817-860-8191.

Sincerely,

/RA/

Roy J. Caniano, Director

Division of Nuclear Materials Safety

Dockets: 050-00133; 072-00027 Licenses: DPR-7; SNM-2514

Enclosure:

NRC Inspection Report 050-00133/11-007; 072-00027/11-001

REGION IV==

Dockets:

050-00133; 072-00027

Licenses:

DPR-7; SNM-2514

Report:

050-00133/11-007; 072-00027/11-001

Licensee:

Pacific Gas and Electric Company

Facility:

Humboldt Bay Power Plant, Unit 3

Location:

1000 King Salmon Avenue

Eureka, California 95503

Dates:

August 1-4, 2011

Inspector:

Robert Evans, PE, CHP, Senior Health Physicist

Repository & Spent Fuel Safety Branch

Approved by: D. Blair Spitzberg, PhD, Chief

Repository & Spent Fuel Safety Branch

Attachment:

Supplemental Inspection Information

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Enclosure EXECUTIVE SUMMARY

Humboldt Bay Power Plant, Unit 3 NRC Inspection Report 050-00133/11-007; 072-00027/11-001

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, with two exceptions as described below.

Organization, Management, and Cost Controls

• The organizational structure was in agreement with Quality Assurance Plan requirements. A sufficient number of staff members were available for the decommissioning activities in progress. Routine technical reviews were being conducted as required by the Quality Assurance Plan and site procedures (Section 1).

• The licensee continued to implement the Request for Information work control process in an effort to help reduce worker errors in the field (Section 1).

Safety Reviews, Design Changes, and Modifications

• The licensees independent safety review program was found to be in compliance with 10 CFR 50.59 requirements. The licensee identified potential conflicts of interest involving independent safety reviewers, but the licensee implemented corrective actions, including procedure revision to correct these potential conflicts of interest (Section 2).

• The licensee had established, implemented, and maintained a fire protection program as required by the license (Section 2).

Self-Assessment, Auditing, and Corrective Action

• The licensee implemented the quality assurance programs in accordance with Quality Assurance Plan requirements (Section 3).

Away-from-Reactor ISFSI Inspection Guidance

• The licensee identified three examples of improper handling of safeguards information.

These three events were identified as two apparent violations of regulatory requirements. The first apparent violation involves the licensees failure to transmit safeguards information in accordance with regulations; the second apparent violation involves two examples of unattended safeguards information within the security area.

The licensee identified the negative trend, voluntarily notified the NRC, and took corrective actions to prevent recurrence (Section 4).

Maintenance and Surveillance

• The licensee conducted operational, maintenance, and surveillance activities in accordance with approved site procedures. Changes to plant systems were conducted in accordance with design change instructions (Section 5).

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Enclosure Decommissioning Performance and Status Review

• During site tours, the inspector confirmed that the licensee continued to implement radiation protection controls in accordance with regulatory requirements (Section 6).

• The licensees decision to issue two stand-down orders, to provide additional site-wide training, and to suspend the reactor pressure vessel chimney lift was considered to be proactive. The licensee wanted to ensure that decommissioning activities were being conducted in a safe and orderly manner (Section 6).

• The licensee continued to implement a cross-contamination control program in accordance with the license (Section 6).

• The licensees corrective actions for a previously missing sealed check source appeared effective to prevent a repeat occurrence (Section 6).

Solid Radioactive Waste Management and Transportation of Radioactive Materials

• The licensee conducted alternate radwaste disposal activities in accordance with the limitations approved by the NRC (Section 7).

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Enclosure Report Details

Summary of Plant Status - Unit 3

Since the previous inspection, the licensee continued to conduct decommissioning activities at the Humboldt Bay Power Plant, Unit 3, in accordance with commitments made in its Post Shutdown Decommissioning Activities Report dated June 30, 2009. At the time of the inspection, limited work activities were in progress because the site was in the middle of a stand-down for retraining of site workers. The stand-down started during mid-July 2011 in response to a near-miss incident that occurred during decommissioning.

Although work activities were limited, the licensees staff continued to prepare the main steam line for sectioning. Workers continued to decontaminate and remove tools and other components from the radiologically restricted area. The licensee continued to prepare for the upcoming chimney lift, a large component that has to be removed from within the reactor cavity.

The licensee also continued to ship wastes for disposal.

In recent months, the licensee completed decommissioning of the fossil plants, Units 1 and 2.

The licensee also installed a new trailer inside of the radiologically restricted area for cleaning of respirators. Finally, the licensee continued to operate a new power generation facility located adjacent to the Unit 3 facility.

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.

1.2 Observations and Findings

a.

Management Organization and Control

The organizational requirements are specified in the Humboldt Bay Quality Assurance (QA) Plan. The inspector reviewed the licensees organizational structure for compliance with QA Plan requirements. The licensee had staffed all management-level 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 was in compliance with QA Plan requirements.

The requirements for the Nuclear Safety Oversight Committee (NSOC) are provided in Appendix B, Section 3, of the QA Plan. The NSOC was required to perform independent reviews of: changes, tests, and experiments; procedures; reportable events; plant trends; and violations of regulatory and license requirements. The NSOC was required to meet at least quarterly. The inspector reviewed the meeting minutes for 2010-2011 and noted that the committee discussed relevant topics during these meetings and took actions as appropriate.

The requirements for the Plant Staff Review Committee (PSRC) are provided in the Defueled Safety Analysis Report and site procedures. The PSRC performed reviews of work tasks with an emphasis on As Low As Reasonably Achievable (ALARA) controls.

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Enclosure The PSRC was also responsible for review of the site emergency plan. The PSRC is required to meet at least quarterly and at other times at the discretion of the chairman.

The committee met numerous times during 2011, and the meetings were a combination of regular and special sessions. The committee members discussed and approved requests to isolate and abandon equipment for decommissioning. The PSRC also conducted evaluations of routine ALARA reviews. The inspector concluded that the licensees PSRC functioned in accordance with Defueled Safety Analysis Report and procedure requirements.

b.

Review of Work Control Processes

The inspector reviewed the licensees work control processes to ensure that decommissioning 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. Included in this procedure is the Request for Information (RFI) process. The RFI process allows workers to request clarification or additional information associated with work orders. The licensee implemented the RFI process to help reduce the number of human errors that were occurring in the field.

The licensee implemented the RFI program during July 2009. Since implementation, 615 RFIs have been created. At the time of this inspection, only four RFIs remained open, indicating that the licensee was effectively reviewing and responding to incoming RFIs.

The inspector reviewed the licensees trending of RFIs. Adverse trends could be representative of work process problems or design flaws that required correction. No adverse trend was apparent, although the licensee was aware that certain work orders had high numbers of RFIs written against them. Any work order with a high number of RFIs may suggest that the work order was not thorough or complete. In these situations, the licensee may elect to rewrite or to revise the work order. In summary, the inspector concluded that the licensee continued to use the RFI process in accordance with procedure requirements.

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 technical reviews were being conducted as required by the QA Plan and site procedures. The licensee continued to implement the RFI work control process in an effort to help reduce worker errors in the field.

Safety Reviews, Design Changes, and Modifications (37801)

2.1 Inspection Scope

The inspector reviewed the licensees safety review and design change processes to verify compliance with the requirements of 10 CFR 50.59.

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Enclosure 2.2 Observations and Findings

a.

Independent Safety Reviews

The inspector conducted an evaluation of the licensees control of independent safety reviews. Independent Safety Reviewers were staff members who were qualified to perform selected reviews such as revisions to procedures. The inspector interviewed several licensee representatives to determine if the licensee was conducting safety reviews in accordance with procedure requirements. Overall, the licensee was conducting the required safety reviews.

The licensee identified a potential problem with the independence of selected safety reviewers. In the past, the licensee allowed some individuals to conduct independent safety reviews, although these individuals worked in the same department that requested the proposed change. The licensee recently initiated an assessment of the definition of an independent safety review, in part because the term independence was not defined. The licensees staff concluded that no adverse consequences were attributed to this independence issue, but future safety reviewers may have to be scrutinized to ensure that the reviewer does not have a stake in the outcome of the review. The licensee elected to revise the applicable site procedure to strengthen the instructions for independent safety reviews. At the end of the inspection period, the licensees revised procedure for independent safety reviews was still in draft.

b.

Review of Fire Protection System Changes

Technical Specification 5.5.1 states, in part, that written procedures shall be established, implemented, and maintained for the fire protection program. In recent months, the licensee significantly downgraded the fire protection system at the site, concurrently with decommissioning of the site structures and equipment. The inspector reviewed the status of the fire protection system to ensure that the system could still fulfill its design function during an emergency or during an analyzed accident. The inspector reviewed site procedures, interviewed the fire marshal, and conducted site tours to determine the status of the fire protection system.

In recent months, the licensee permanently removed the raw water storage tank, fire pumps, and all Unit 1 and Unit 2 components from service. The licensee connected the plants fire protection piping to municipal water supplied by the Humboldt Community Service District. This water supply source was determined to have the required pressure and volume needed to fight an onsite fire.

At the time of the inspection, the fire protection system consisted of yard hydrants, building sprinklers, and hand-held fire extinguishers. According to the fire marshal, there were sufficient sources of fire suppression capability for the protection of Unit 3 decommissioning activities. In addition, the fire department had access to the raw water storage tank at the new generation facility if needed. The fire protection system hardware was supplemented with administrative controls, including routine monitoring by the fire marshal, control of combustibles entering the radiologically restricted area, and inspection of equipment such as hand-held fire extinguishers and valve lineups.

The inspector reviewed the fire hazard analysis and interviewed the fire marshal to ensure that the current design of the fire protection system was capable of combating

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Enclosure these analyzed accidents. The analyzed accidents are described in Appendix D to the Defueled Safety Analysis Report. The accidents include dry active waste fire, liquid propane gas explosion, oxyacetylene tank explosion, high efficiency particulate air filter fire, and detonation of unused concrete blasting explosives. The fire hazard analysis evaluated the various fire hazards and the capability of the fire protection system to counteract these hazards. The analysis concluded that the capability of the fire protection system was sufficient to support decommissioning activities.

The inspector reviewed the site emergency plan to ensure that the plan correctly reflected the current condition of the fire protection system. The emergency plan was found to be up to date. The inspector also reviewed site emergency procedures to determine if the procedures correctly reflected the as-built conditions in the field.

Procedure EOP-4, Plant Fire and/or Explosion, Revision 32A, provided the instructions for combating a fire. This emergency procedure was also found to be up to date. This emergency procedure included instructions for radiation protection support, as necessary, in response to a fire.

The inspector concluded that the licensee had sufficient fire suppression capacity for the types of fires that may occur in Unit 3. Site procedures, drawings, and the fire hazard analysis were all up to date and reflected the current conditions in the field.

2.3 Conclusions

The licensees independent safety review program was found to be in compliance with 10 CFR 50.59 requirements. The licensee identified potential conflicts of interest involving independent safety reviewers, but the licensee implemented corrective actions, including procedure revision, to correct these potential conflicts of interest. The licensee had established, implemented, and maintained a fire protection program as required by the license.

Self-Assessment, Auditing, and Corrective Action (40801)

3.1 Inspection Scope

The inspector evaluated the effectiveness of the licensee to identify, resolve, and prevent issues that could degrade safety or the quality of decommissioning.

3.2 Observations and Findings

Technical Specifications, an appendix to the license, requires the implementation of the QA Plan. The QA program requirements include routine audits, independent assessments, and observations of work in progress. The inspector reviewed the licensees implementation of its QA Plan to ensure that decommissioning activities were being conducted with an emphasis on quality.

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Enclosure Section 18 of the QA Plan specifies the program areas that were required to be audited on a routine basis. The licensee maintained an audit matrix to track the required audits and the audit frequencies. The inspector reviewed the audit schedule and discussed the schedule with an onsite 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 several previously completed audits. No major deficiencies or violations of regulatory requirements were identified by the auditors. The inspector confirmed that audit findings were being documented in the licensees SAP notification (problem reporting) system for correction.

One recent audit focused on site decommissioning. The auditors concluded that decommissioning records did not always meet the criteria for retrieval and storage of quality records. Also, plant design changes were not always being reflected in site procedures in a timely manner. The licensee issued SAP notifications (problem reports)

to investigate and to correct these audit findings.

In addition to formal audits, the QA and quality control staff conducted independent assessments and observations of decommissioning work in progress. The inspector reviewed selected quality verification assessments and concluded that the observations were comprehensive. One recent assessment, for example, reviewed the corrective action programs of the decommissioning contractors. The auditor noted that the various programs were not always integrated when problems were identified. Corrective actions were taken by the licensee to resolve these program discrepancies.

The licensee also recently conducted an assessment of the NSOC program, a program required by the QA Plan. The inspector discussed this assessment with QA representatives. The assessment did not identify any major deficiencies, but the audit identified a number of enhancements to the NSOC program.

3.3 Conclusions

The licensee implemented the QA programs in accordance with QA Plan requirements.

Away-from-Reactor ISFSI Inspection Guidance (60858)

4.1 Inspection Scope

The inspector determined whether the licensee was operating and maintaining the independent spent fuel storage installation (ISFSI) programs in conformance with license requirements.

4.2 Observations and Findings

On July 20, 2011, the licensee contacted the NRC Region IV office to discuss its discovery of a negative trend involving safeguards information (SGI). In response to this notification, the inspector conducted a follow up review of several incidences involving the improper handling of SGI by licensee representatives, including:

• Documents marked as SGI were left unattended within the ISFSI security area on May 4, 2011

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Enclosure

• A box stamped safeguards information was required to be shipped as a double wrapped package but was actually shipped without the outer packaging on May 27, 2011

• Safeguards information was left unattended in a locked room by a contractor in Building 11 at the ISFSI on June 27, 2011

10 CFR 73.22(f)(1) requires, in part, that documents containing Safeguards Information, when transmitted outside an authorized place of use or storage, must be packaged in two sealed envelopes or wrappers to preclude disclosure of the presence of protected information. The outer envelope or wrapper must be opaque, and may not bear any markings or indication that the document contains Safeguards Information.

On May 27, 2011, the licensee failed to transmit Safeguards Information outside an authorized place of use or storage in two sealed envelopes or wrappers to preclude disclosure of the presence of protected information. Specifically, the licensee failed to use an opaque outer wrapper when it transmitted a box of documents containing Safeguards Information that was clearly stamped Safeguards Information on the single outer wrapper. The licensees failure to properly transmit SGI outside of the authorized place of use or storage was identified as an apparent violation of 10 CFR 73.22(f)(1)

(APV 072-00027/1101-01).

As noted above, the license identified two instances where SGI was left unattended within the security area. Condition 12 of License SNM-2514, states that the licensee shall follow the physical protection plan entitled, Humboldt Bay Independent Spent Fuel Storage Installation Physical Security Plan. Chapter 1, Page 6 of Humboldt Bay Independent Spent Fuel Storage Installation Physical Security Plan, Revision 4, states, in part, that implementing procedures are written and maintained to provide detailed instructions for personnel responsible for implementing and enforcing the Physical Security Plan. Security Procedure I-SP-112, Controlled Security Documents, Revision 2, Section 2.3.1, states, in part, that positive control must be maintained over safeguards information at all times. Positive control includes being in the physical possession of an authorized individual or locked in an approved storage container.

On May 4 and again on June 27, 2011, the licensee failed to maintain physical control of safeguards information per Security Procedure I-SP-112 by having the information either in the physical possession of an authorized individual or locked in an approved storage container. Specifically:

• Documents marked as Safeguards Information were left unattended within the ISFSI security area on May 4, 2011; and,

• Documents marked as Safeguards Information were left unattended in a locked room, located in the ISFSI access Building 11 on June 27, 2011

The licensees failures to implement the requirements of Security Procedure I-SP-112 on May 4 and June 27, 2011, were identified as two examples of an apparent violation of Condition 12 of License SNM-2514 (APV 072-00027/1101-02).

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Enclosure

The licensee identified, logged, investigated, and corrected the three events. The licensee identified a negative trend involving SGI and initiated an adverse trend investigation. The licensee attributed the cause of the three events to human error. The licensee provided the NRC with a courtesy notification. No actual consequences occurred as a result of the loss of control of SGI, although the potential for unauthorized access to SGI existed in one of three examples.

The licensee implemented corrective actions that included remedial training, visual reminders (yellow chains), and procedure revision. Training included an expectation that the transmittal of SGI materials will be accomplished with the implementing procedure in hand to ensure that the documents will be packaged and shipped in accordance with procedure requirements. One procedure change included the requirement that all external shipments of SGI will be verified by a supervisor or manager prior to actual shipment.

4.3 Conclusions

The licensee identified three examples of improper handling of SGI. These three events were identified as two apparent violations of regulatory requirements. The first apparent violation involves the licensees failure to transmit SGI in accordance with regulations; the second apparent violation involves two examples of unattended SGI within the security area. The licensee identified the negative trend, voluntarily notified the NRC, and took corrective actions to prevent recurrence.

Maintenance and Surveillance (62801)

5.1 Inspection Scope

The inspector conducted a review of selected operational, maintenance, and surveillance activities to ensure that the licensee continued to operate and maintain plant systems still in service.

5.2 Observations and Findings

At the time of the inspection, the licensee continued to operate and maintain selected plant systems. The systems still in service included power distribution, fire protection, instrument air, ventilation, and water supply systems. The inspector reviewed the licensees ability to operate and to maintain systems during decommissioning. The licensee continued to provide dedicated staff for plant operations and for system maintenance. During site tours, the inspector observed equipment in operation, and the inspector concluded that the licensee continued to operate the remaining equipment in accordance with procedure requirements.

The inspector reviewed the status of two plant systems still in service, the instrument air system and the radioactive liquid effluent monitoring system. In recent months, the radioactive liquid effluent monitoring system failed its routine surveillance test due to communication errors between the radiation detector and the corresponding control panel. This system was needed to support liquid effluent releases. According to the licensees records, the electronics failed six times since 2007, prompting the licensee to declare the system inoperable.

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Enclosure The licensee elected to modify the system by replacing the old multi-channel analyzer with a new single-channel analyzer. The new analyzer was expected to be more reliable than the previous analyzer. The licensees Plant Staff Review Committee approved the design change during June 2011.

During the inspection, the licensee was installing the new single channel analyzer. The inspector observed the analyzer and compared the work completed to the instructions provided in the applicable design change notice. The inspector concluded that the work was being conducted in accordance with work instructions. At the end of the onsite inspection, the licensee had not completed the installation and startup testing of the analyzer; therefore, the operability of the new analyzer will be reviewed during a future inspection.

As part of the decommissioning process, the licensee previously implemented cold and dark conditions in Unit 3 to allow for demolition and removal of plant equipment. The licensee provided temporary power and other support services for equipment still in service. After implementation of temporary services, the licensee recognized that improved instrument air supply capability was needed to support equipment located in the liquid radwaste building. During the inspection, the licensee was in the final phases of constructing the upgraded instrument air system for the liquid radwaste building. The new system consisted of an air compressor and the air supply tubing connecting the various components that needed instrument air to operate. The inspector conducted a walk-down of the system with licensee representatives. The inspector concluded that the system had been installed as stipulated in the applicable design change notice.

5.3 Conclusions

The licensee conducted operational, maintenance, and surveillance activities in accordance with approved site procedures. Changes to plant systems were conducted in accordance with design change instructions.

Decommissioning Performance and Status Review (71801)

6.1 Inspection Scope

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

6.2 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, calibration due date of 01/03/12). The inspector did not identify any radiation area that was incorrectly posted by the licensee.

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Enclosure b.

Review of Decommissioning Activities

The inspector conducted a follow up review of selected decommissioning activities, including two recent stand-downs. The inspector also conducted a review of the reactor pressure vessel decommissioning work.

During May 2011, the licensee recognized a negative trend in work performance, and the licensee conducted a safety stand-down at that time. The May 2011 stand-down was initiated in response to 12 near-miss events that occurred during decommissioning.

The events included a mercury spill, inadvertent cutting of a sulfuric acid line, and three recent puncture wounds. During the stand-down, the licensee discussed the various events with site personnel. The stand-down lasted about 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

However, the licensee initiated another stand-down during mid-July in response to another near-miss incident. On July 11, 2011, a worker accidently cut and dropped a spring can pipe support. The accident was considered significant, in part because workers were situated in the area when the spring can was dropped. Although no one was injured, this incident had the potential for serious worker injury. In addition, while falling, the spring can hit the main steam piping which increased the potential for airborne contamination.

In response to the dropped spring can incident, the licensee subsequently elected to take extensive corrective actions, including removal of the decommissioning contractor work force from the site. Additional corrective actions included a team technical review and a root cause analysis. The licensee elected to hold numerous meetings with site staff to ensure that workers understood the ramifications of the incident as well as management expectations for working safely. The licensee subsequently elected to hire a different contractor to provide oversight of future decommissioning work.

At the end of the onsite inspection, the stand-down was still in effect. The licensee was expected to retrain the new contractor work force and to lift the stand-down in the next few weeks. The inspector concluded that the stand-down was a proactive response taken by licensee management to protect workers from unsafe work practices. The licensees implementation of its corrective actions for this stand-down will be reviewed during a future inspection.

Since the previous inspection, the licensee continued to conduct work on the reactor pressure vessel, a critical path activity. As part of this work, the licensees contractor attempted to lift the reactor vessel chimney out of the reactor during mid-July 2011 and place the chimney in the spent fuel pool. Once in the spent fuel pool, the licensee planned to section the chimney for disposal. However, during the lift, the chimney tilted approximately 8 degrees off center. Because of tight clearances in the reactor cavity, licensee management elected to suspend the lift to avoid the possibility of the chimney becoming stuck in place. In addition, the chimney was highly radioactive, and the licensee wanted to avoid having the chimney stuck in a position that would create airborne radioactivity and high radiation areas.

The chimney was lowered back into its original position. The cause of the tilt was partially attributed to the location of the lifting points on the chimney. The lift points are located at the bottom, not the top, of the chimney. In response to the unanticipated

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Enclosure tilting of the chimney, the licensee elected to implement further reviews for lifting the chimney. The review will consider new or upgraded lifting points, rigging instructions, hazards analysis, and emergency instructions. At the end of the onsite inspection, the licensee had not completed its reviews and program upgrades for lifting the chimney.

The licensees implementation of its revised plans for lifting the chimney will be reviewed during a future inspection.

c.

Status of Cross-Contamination Prevention and Monitoring Plan

License Condition 2.C.4 requires the licensee to implement a cross-contamination prevention and monitoring plan for the new fossil fuel generation facility. The inspector reviewed the licensees implementation of its cross-contamination plan. The plan requires the licensee to conduct quarterly radiological surveys to ensure that the decommissioning of Unit 3 was not causing cross-contamination of the new power generation facility. The licensee developed a surveillance test procedure for the survey.

The first quarterly survey was conducted during July 2009. The most recent quarterly radiological survey was completed during mid-June 2011. The inspector reviewed the June 2011 survey results. All survey results were less than the investigation level.

These results suggest that the licensee was effectively preventing the cross-contamination of the new generation facility. In summary, the inspector concluded that the licensee continued to conduct the cross-contamination prevention plan in accordance with license requirements.

d.

Revised Licensee Event Report for Lost Calibration Source

During June 2010, the licensee became aware that it was missing a radioactive sealed source. The missing check source was a mixed gamma radiation source used for calibration of gamma detecting meters. At that time, the licensee conducted a search for the source but failed to locate it. The licensee subsequently reported the source as missing to the NRC by Licensee Event Report dated August 20, 2010. The licensees loss of control of the radioactive material was identified as a violation of 10 CFR 20.1802 requirements. The NRC subsequently issued a noncited violation for the missing check source by NRC Inspection Report 050-00133/10-004 dated September 28, 2010.

However, on February 1, 2011, the licensee found the missing sealed source in a measuring and test equipment storage locker. The licensee subsequently submitted a revised Licensee Event Report to the NRC by letter dated July 14, 2011.

The inspector conducted a follow up review of the licensees corrective actions for the lost source. The licensee determined that the root cause of the event was inadequate radiation protection procedures to ensure control of radioactive sources. The inspector confirmed that the licensee updated the procedure for inventory and control of radioactive sources. Program changes included installation of new storage lockers and the implementation of a new administrative requirement for double verification for removal of sources from the storage lockers. The inspector observed the new storage lockers and the new check-out/check-in process. These corrective actions appear effective to prevent a future loss of control of radioactive material.

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Enclosure 6.3 Conclusions

During site tours, the inspector confirmed that the licensee continues to implement radiation protection controls in accordance with regulatory requirements. The licensees decision to issue two stand-down orders, to provide additional site-wide training, and to suspend the reactor pressure vessel chimney lift was considered to be proactive. The licensee wanted to ensure that decommissioning activities were being conducted in a safe and orderly manner. The licensee continued to implement a cross-contamination control program in accordance with the license. Finally, the licensees corrective actions for a previously missing sealed check source appeared effective to prevent a repeat occurrence.

Solid Radioactive Waste Management and Transportation of Radioactive Materials (86750)

7.1 Inspection Scope

The inspector reviewed the licensees programs for characterizing, packaging, and shipping the radioactive wastes generated during site decommissioning.

7.2 Observations and Findings

The inspector reviewed the licensees implementation of its alternate waste disposal program that was recently approved by the NRC for disposal of certain wastes containing low levels of radioactive contamination. These wastes included concrete, steel, insulation, roofing material, and other debris from Units 1 and 2, as well as selected components from Unit 3.

By letter dated April 1, 2010, the licensee requested alternate disposal of approximately 200,000 cubic feet of these wastes at a Resource Conservation and Recovery Act (RCRA) hazardous disposal facility located in Idaho. The request was made under the alternate disposal provision contained in 10 CFR 20.2002. By letter dated November 2, 2010, the NRC approved the licensees request.

The inspector reviewed selected shipping records and interviewed shipping department staff to ensure that the licensee was in compliance with the alternate disposal provisions that were authorized by the NRC. The provisions included limitations on the concentrations of radionuclides in the wastes and the total quantity of material allowed to be disposed at the RCRA facility.

The inspector reviewed the shipping records of selected components to ensure that the material met the criteria for disposal at the RCRA facility. The inspector reviewed four shipping records for the Unit 3 drywell shield blocks. The records included shipping papers, bills of lading, and survey records. The licensee classified the material as eligible for disposal at the RCRA facility based on slurry material collected during the cutting of the concrete shield into blocks. This slurry material was analyzed by an offsite laboratory. The analysis indicated that the slurry material contained 5.5 picocuries per gram (pCi/g) of cesium-137 and 0.095 pCi/g of cobalt-60. The alternate disposal limits were 15 pCi/g for cesium-137 and 5 pCi/g for cobalt-60. In summary, the shield block sections met the criteria for disposal at the RCRA facility.

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Enclosure

The inspector reviewed the licensees shipment records to ensure that the total volume of material shipped did not exceed the 200,000 cubic feet limit. At the time of the onsite inspection, the licensees records indicated that it had shipped slightly over 82,000 cubic feet of material in 160 individual shipments. In summary, the amount of material shipped was less than the disposal limit.

In the near future, the licensee plans to begin demolition of the Unit 3 turbine building.

The licensee believes that much of the building demolition debris and some soils from Unit 3 will meet the criteria for disposal at the RCRA facility. The licensee submitted an additional alternate disposal request to the NRC by letter dated June 7, 2011. The licensee requested NRC approval to dispose up to 2,000,000 cubic feet of material at the RCRA facility. This request was similar to the previous request previously approved by the NRC. At the end of the inspection period, the NRC was still reviewing the licensees request.

7.3 Conclusions

The licensee conducted alternate radwaste disposal activities in accordance with the limitations approved by the NRC.

Exit Meeting

The inspector reviewed the scope and preliminary findings of the inspection during an exit meeting conducted at the conclusion of the onsite inspection on August 4, 2011. A final exit briefing was held with licensee representatives by telephone on September 23, 2011. 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

B. Arroyo, Site Services Manager B. Barley, Final Status Survey Supervisor A. Berry, Radwaste Supervisor J. Chadwick, Radiation Protection Supervisor J. Costantino, General RP Foreman A. Cordone, Decommissioning Projects Superintendent J. Griffin, Licensing Engineer S. Jones, QA Supervisor G. Mason, Decommissioning Work Control S. McDonald, Safety/IH Department Supervisor K. Rod, Decommissioning Manager P. Roller, Director and Nuclear Plant Manager S. Schlerf, Radiation Protection Forman B. Sicotte, QC Supervisor M. Smith, Engineering Manager D. Sokolsky, Licensing Supervisor

INSPECTION PROCEDURES USED

36801 Organization, Management, and Cost Controls at Permanently Shutdown Reactors

37801 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors

40801 Self-Assessment, Auditing, and Corrective Action at Permanently Shutdown Reactors

60858 Away-from-Reactor ISFSI Inspection Guidance

62801 Maintenance and Surveillance at Permanently Shutdown Reactors

71801 Decommissioning Performance and Status Review at Permanently Shutdown Reactors

86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

072-00027/1101-01 APV Failure to properly package SGI for shipment

072-00027/1101-02 APV Failure to maintain control of SGI

Attachment

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Closed

None

Discussed

None

LIST OF ACRONYMS

ALARA as low as reasonably achievable CFR

Code of Federal Regulations ISFSI independent spent fuel storage installation NSOC Nuclear Safety Oversight Committee pCi/g picocuries per gram PEC

predecisional enforcement conference PSRC Plant Staff Review Committee QA

quality assurance RCRA Resource Conservation and Recovery Act RFI

Request for Information SGI

safeguards information