IR 05000219/2024002
| ML24239A805 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 09/05/2024 |
| From: | Eve E Decommissioning, ISFSI, and Reactor Health Physics Branch |
| To: | Trice K Holtec Decommissioning International |
| References | |
| IR 2024002, IR 2024001 | |
| Download: ML24239A805 (1) | |
Text
September 5, 2024
SUBJECT:
HOLTEC DECOMMISSIONING INTERNATIONAL, LLC, OYSTER CREEK NUCLEAR GENERATING STATION - NRC INSPECTION REPORT NO.
05000219/2024002 AND 07200015/2024001
Dear Kelly Trice:
On June 30, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection under Inspection Manual Chapter 2561, Decommissioning Power Reactor Inspection Program, at the permanently shut down Oyster Creek Nuclear Generating Station (Oyster Creek). The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and the conditions of your license. The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records, and plant walk-downs. The results of this inspection were discussed with Jeffrey Dostal, Site Vice President, and other members of your staff on July 25, 2024, and are described in the enclosed report.
Within the scope of this inspection, no violations of more than minor safety significance were identified.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure, and your response (if any)
will be made available electronically for public inspection in the NRC Public Document Room or from the NRC document system (ADAMS), accessible from the NRC website 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.
Current NRC regulations and guidance are included on the NRCs website at www.nrc.gov; select Radioactive Waste; Decommissioning of Nuclear Facilities; then Regulations, Guidance and Communications. The current Enforcement Policy is included on the NRCs website at www.nrc.gov; select About NRC, Organizations & Functions; Office of Enforcement; Enforcement documents; then Enforcement Policy (Under Related Information). You may also obtain these documents by contacting the Government Printing Office (GPO) toll-free at 1-866-512-1800. The GPO is open from 8:00 a.m. to 5:30 p.m. EST, Monday through Friday (except Federal holidays).
K Trice
No reply to this letter is required. Please contact Andrew Taverna of my staff at 610-337-5119 if you have any questions regarding this matter.
Sincerely, Elise Eve, Team Leader Decommissioning Team Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Radiological Safety and Security
Docket No:
05000219 and 07200015 License No: DPR-16
Enclosure: Inspection Report Nos. 05000219/2024002 and 07200015/2024001
w/Attachment
cc w/encl: Distribution via ListServ ELISE EVE Digitally signed by ELISE EVE Date: 2024.09.05 09:49:33 -04'00'
EXECUTIVE SUMMARY
Holtec Decommissioning International, LLC (HDI)
Oyster Creek Nuclear Generating Station (Oyster Creek)
NRC Inspection Report Nos. 05000219/2024002 and 07200015/2024001
A routine announced decommissioning inspection was completed on June 30, 2024, at the permanently shut down Oyster Creek. A combination of on-site and remote inspection activities was performed over the inspection period. On-site inspection activities were conducted on April 15 - 18 and June 10 - 14, 2024. The inspection included safety reviews, design changes, and modifications at permanently shutdown reactors, problem identification and resolution, decommissioning performance, and status reviews; occupational radiation exposure; and solid radioactive waste management and transportation of radioactive materials. The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records, and plant walk-downs. The U.S. Nuclear Regulatory Commissions (NRC) program for overseeing the safe decommissioning of a shutdown nuclear power reactor is described in Inspection Manual Chapter (IMC) 2561, Decommissioning Power Reactor Inspection Program.
Additionally, the inspection period included follow-up on traditional enforcement actions in accordance with 10 CFR 2.201, Notice of Violation, where enforcement sanctions typically require written explanations and statements of reply concerning corrective actions, steps taken to prevent recurrence, and a schedule for completion of corrective and preventive actions.
Furthermore, inspectors included a review and observation of the Independent Spent Fuel Storage Installation (ISFSI) pad and loaded casks. The NRCs program for overseeing the operation of dry storage of spent fuel at an ISFSI is described in IMC 2690, Inspection Program for Storage of Spent Reactor Fuel at Independent Spent Fuel Storage Installations and for Title 10 of the Code of Federal Regulations (10 CFR) Part 71 Transportation Packagings.
Based on the results of this inspection, no violations of more than minor safety significance were identified.
REPORT DETAILS
1.0 Background
On September 25, 2018, Oyster Creek certified the permanent removal of fuel from the reactor vessel (Agencywide Document Access and Management System (ADAMS)
Accession No. ML18268A258). This met the requirements of 10 CFR 50.82(a)(1)(i) and 50.82(a)(1)(ii). On October 1, 2018, the NRC notified the licensee that the Operating Reactor Assessment Program had ceased, and that implementation of the Decommissioning Power Reactor Inspection Program would begin on October 1, 2018 (ADAMS Accession No. ML18274A221). On July 1, 2019, an amended license was issued transferring the license from Exelon Generation Co., LLC to Holtec Decommissioning International, LLC (ADAMS Accession No. ML19164A157). Oyster Creek is currently in the Actively Decommissioning, No Fuel in the Spent Fuel Pool (SFP) phase of decommissioning as described in IMC 2561.
2.0 Active Decommissioning Performance and Status Review
2.1 Inspection Procedures 37801, 40801, 71801, 83750, 86750
a. Inspection Scope
The inspectors performed on-site decommissioning inspection activities April 15 - 18 and June 10 - 14, 2024, supplemented by in-office reviews and periodic phone calls during the inspection period. The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records, and plant walk-downs.
The inspectors reviewed a sample of 10 CFR 50.59 documents to determine if HDIs procedures and processes were following the regulations and guidance associated with 10 CFR 50.59. The review included HDIs applicability determination process that is used to determine if a 10 CFR 50.59 evaluation was required.
The inspectors attended Holtec meetings, interviewed Oyster Creek personnel, and reviewed a sampling of issues, non-conformances and conditions adverse to quality to assess the implementation and effectiveness of Holtecs Corrective Action Program (CAP). The inspectors reviewed a representative selection of CAP documents to determine if a sufficiently low threshold for problem identification existed, if follow-up evaluations were of sufficient quality, and if Holtec assigned timely and appropriate prioritization for issue resolution commensurate with the significance of the issue.
The inspectors reviewed documentation and discussed with HDI the overall financial status of decommissioning for Oyster Creek and evaluated the use of decommissioning trust funds to determine if they were appropriately used in accordance with regulatory requirements. The inspectors also discussed any significant changes to the estimated cost for, and any potential significant delays to, the decommissioning schedule.
The inspectors attended select management meetings, including station oversight committee and management review committee meetings. Inspectors reviewed documentation and met with Oyster Creek management to discuss staffing, training, status of decommissioning and upcoming activities to determine if HDI had conducted activities in accordance with regulatory requirements. The inspectors performed several plant walk-downs to assess field conditions and decommissioning activities by evaluating material condition of structures, systems, and components; housekeeping; system configurations; and worker level of knowledge and procedure use and adherence. These walk-downs included the New Radwaste (NRW) building, reactor building, and the radiologically controlled area (RCA) yard. Additionally, the inspectors observed select pre-job briefings and associated work activities, including but not limited to 119 Refuel floor activities that involved clean-up, movement of an A-box onto the refuel floor, removal of tri-nuke filter racks, movement of Equipment Storage Pit (ESP)protection plates, characterization surveys of the reactor pressure vessel, and hot work activities in NRW.
The inspectors observed activities, reviewed documentation, and interviewed personnel associated with occupational radiation exposure to evaluate the licensees protection of worker health and safety as well as the staffing of the radiological protection department.
The inspectors conducted site walk-downs, including radiologically controlled areas, to examine and verify radiological postings, and airborne and contamination controls. The inspectors reviewed Radiation Work Permits (RWPs) and As Low As Reasonably Achievable (ALARA) work plans to determine if radiation work activities were pre-planned effectively to limit worker exposure. Inspectors also attended various briefings where radiological and industrial safety during work activities were discussed such as an ALARA and Activity plan meeting. The inspectors observed Radiation Protection (RP) staff perform work activities. The inspectors observed the RP coverage during the following work activities:
- (1) Hot-work in NRW,
- (2) 119 Cavity clean-up activities on the refuel floor,
- (3) removal of tri-nuke filter racks on the refuel floor, (4)movement of the ESP protection plates on the refuel floor,
- (5) characterization surveys of the reactor pressure vessel. Additionally, the inspectors observed staff donning and doffing protective clothing, using portal exit monitors out of the RCA, and an RP technician demonstrating knowledge and use of an RO-20 instrument when confirming general area dose rates. During the inspectors walk-down of the reactor building and new radwaste building, a sample of instruments was checked for their condition and calibration. Additionally, the inspectors entered a High Radiation Area (HRA) to assess conditions in the southeast corner room underneath the Torus to determine if the site had appropriate radiological controls, including postings and control points, and if ambient radiological conditions were consistent with radiological postings. Inspectors discussed with site personnel RP controls regarding the tent setup in the heat exchanger area where a new entryway was created into NRW.
Inspectors discussed with site management source-term characterization to determine if Oyster Creek had adequate knowledge of the gamma (photon) spectrum, the beta spectrum and average beta energy of the beta spectrum, the Hard-to-detect (HTD)component of beta/gamma activity, and the alpha transuranic component of the source term.
The inspectors performed walkdowns of radioactive material storage areas to assess the effectiveness of Oyster Creeks handling and storage of radioactive material and to assess conditions of the area. Additionally, inspectors reviewed a list of sources from the sites inventory and performed walk-downs of the source locations to evaluate if the sources were accounted for and determined to be intact. Inspectors reviewed a sample of shipment manifests to determine if the packages had been appropriately characterized, classified, and prepared in accordance with procedures and regulatory requirements.
b. Observations and Findings
The inspectors verified the effectiveness of the CAP process at Oyster Creek. The inspectors determined that issues were being identified and entered into the CAP in a timely manner and the issues were effectively screened, prioritized and evaluated commensurate with their safety significance. The inspectors determined an appropriate process exists for the resolution of employee concerns and did not identify any safety conscious work environment concerns.
The inspectors reviewed financial assurance documentation, including the annual report on the status of decommissioning funding, and met with site staff to determine whether the funds were used in accordance with the regulatory requirements and if any changes could significantly impact the sites decommissioning financial assurance. The inspection of the DTF will continue into the third quarter as an open item (Open Item 0500219-2024002-001, Continued Review of HDI's Use of Oyster Creek Decommissioning Trust Funds).
The inspectors noted that during this inspection period, the site continued decommissioning and dismantlement activities in the new radwaste building and reactor building. The inspectors noted that for the areas of the plant toured, the material condition and housekeeping was adequate. The inspectors determined through plant tours, document reviews, and observations that HDI conducted activities in accordance with the regulatory requirements. The inspectors noted that workers were knowledgeable of and adhered to plant procedures and work plans, and pre-job briefings were thorough and highlighted specific safety concerns.
The inspectors determined that the RWPs and ALARA work plans were implemented to limit worker exposure. The inspectors determined that RP staff adequately demonstrated knowledge and practice of site procedures and controls during observed work activities and used appropriate equipment during those work activities. Inspectors noted during observations, the RP personnel conducted continuous instrument dose rate measurements on the refuel floor in the reactor building, and work areas in NRW. The licensee plans for the work were commensurate with the risk of the work and associated hazards. The inspectors determined that selected instruments during walk-downs were in calibration and in working condition. The HRA entered in the southeast corner room underneath the Torus, inspectors determined that the site had appropriate radiological controls, including postings and control points, and ambient radiological conditions were consistent with radiological postings.
Inspectors determined that Oyster Creek has adequate knowledge of the gamma (photon) spectrum, the beta spectrum and average beta energy of the beta spectrum, the HTD component of beta/gamma activity, and the alpha transuranic component of the sites source term. The site uses various surveys around the site, characterization data and walkover scans, presence of radioactive nuclide decay on the refuel floor, gamma spectroscopy measurements, gross alpha/beta activities, liquid scinitillation, and Part 61 analyses. In addition, data from characterization of the drywell and characterization of buried and embedded pipping will be used to understand source term. Furthermore, the site maintains maps of Alpha level 1, 2, and 3 areas and develops plans based on specific hazards or projects such as ALARA and Total Effective Dose Equivalent (TEDE)
ALARA plans to determine if there is a decrease or increase in emitting radionuclides.
The inspectors determined that solid radioactive waste was adequately stored, monitored, and the areas were maintained. Additionally, inspectors determined the sites inventory of sources were accounted for and to be intact. The shipment manifests were determined to be appropriately characterized, classified, and prepared in accordance with procedures and regulatory requirements.
c. Conclusion
No violations of more than minor safety significance were identified.
2.2 Inspection Procedure 92702, Follow-up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, and Orders
a. Inspection Scope
Inspectors conducted onsite follow-up regarding Enforcement Action, (EA-23-076) found in NRC Inspection Report No. 05000219/2023002 (ADAMS ACCESSION NO. ML23214A247) on April 11 - 15, 2024. EA-23-076 involved the failure by Holtec Decommissioning International, LLC (HDI) staff at Oyster Creek to design and prepare radioactive materials for shipment so that under conditions normally incident to transportation the radiation level does not exceed 200 mrem/hr at any point on the external surface of the package, as required by Title 49 of the Code of Federal Regulations (49 CFR) 173.441. Pursuant to 10 CFR 71.5, licensees who transport licensed materials on public highways must comply with the requirements of the U.S.
Department of Transportation regulations in 49 CFR Parts 170 through 189.
Inspectors conducted documentation reviews, interviews and discussions with site staff and management to determine if adequate corrective actions have been implemented for the enforcement action (EA-23-076). Additionally, inspectors discussed any causal factors, extent-of-condition, or extent-of-cause related to the enforcement action to determine if they have been identified, that their generic implications have been addressed, and that the licensees programs and practices have been appropriately enhanced to prevent recurrence.
The documentation reviews included but were not limited to relevant inspection reports and Notice of Violation, communications, licensee response letter to enforcement correspondence, commitments/actions, site procedures, and any other records of communications on the issue with Oyster Creek.
b. Observations
The inspectors determined HDI had adequately implemented corrective measures.
Additionally, inspectors determined that the sites programs and practices have been appropriately enhanced based on the sites causal analyses.
c. Conclusions
No violations of more than minor safety significance were identified. The inspectors determined HDIs actions and responses reviewed during the follow-up on the traditional enforcement action to be adequate and the matter closed.
3.0 Independent Spent Fuel Storage Installation (ISFSI)
3.1 Operation of an Independent Spent Fuel Storage Installation (Inspection Procedure 60855)
a. Inspection Scope
The inspectors evaluated HDIs activities related to long-term operation and monitoring of their independent spent fuel storage installation on March 18 - April 5, 2024. The inspectors reviewed radiation protection procedures, corrective action program documents, cask ventilation and temperature monitoring devices, and material conditions of the ISFSI pad and loaded casks.
b. Conclusions
No violations of more than minor safety significance were identified.
4.0 Exit Meeting
On July 25, 2024, the inspectors presented the inspection results to Jeffrey Dostal, Site Vice President, and other members of the Oyster Creek staff. No proprietary information was retained by the inspectors or documented in this report.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Oyster Creek Personnel
- S. Johnson, Site Licensing Manager
- W. Straka, Project Manager
- M. Hassler, Decommissioning Manager
- K. Leonard, Waste Controls Manager
- J. Sisak, Decommissioning Facility Manager
- M. Carlson, Site Engineering Manager
- E. OBrien, Environmental Spec/Safety
- K. Wolf, Radiation Protection, Chemistry, and Environmental Manager
- F. Miranda, Shipping Specialist
- J. Murphy, Radiation Protection, Chemistry Supervisor
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
Section Summary
- 05000219/2024002-01 2.1. b Continued Review of HDIs Use of Oyster Creek Decommissioning Trust Fund
PARTIAL