ML092230614

IR 05000133-09-002, on July 13-16, 2009, Humboldt Bay Power Plant Unit 3 Facility

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.

PG&E

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

Sierra Club California

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

ADAMS

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.:

DPR-7

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

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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

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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

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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

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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

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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

cesium-137.

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

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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

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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

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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

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ATTACHMENT

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LIST OF ACRONYMS

ALARA

As Low As Reasonably Achievable

CFR

Code of Federal Regulations

DSAR

Defueled Safety Analysis Report

HBPP

Humboldt Bay Power Plant

IP

Inspection Procedure

PSDAR

Post Shutdown Decommissioning Activities Report

SFP

Spent Fuel Pool