IR 05000302/2021004: Difference between revisions

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=Text=
=Text=
{{#Wiki_filter:UNITED STATES NU CLE A R RE GU L ATO R Y CO MMISSION
{{#Wiki_filter:January 24, 2022
 
==REGION I==
2 100 R EN AI S SANC E BLVD.
 
KIN G OF P RUSSI A, PA 19406-2713


==SUBJECT:==
==SUBJECT:==
ACCELERATED DECOMMISSIONING PARTNERS (ADP) CR3, LLC, CRYSTAL RIVER UNIT 3 - NRC INSPECTION REPORT NO. 05000 302/20 2100 4
ACCELERATED DECOMMISSIONING PARTNERS (ADP) CR3, LLC, CRYSTAL RIVER UNIT 3 - NRC INSPECTION REPORT NO. 05000302/2021004


==Dear Mr. Reid:==
==Dear Mr. Reid:==
On December 31, 2021, the U.S. Nuclear Regulatory Commission (NRC ) completed an inspection under Inspection Manual Chapter 2561, Decommissioning Power Re actor Inspection Program," at the permanently shut down Crystal River Nuclear Plant Unit 3 (CR-3). A combination of on-site and remote inspection activities (in-office reviews) were pe rformed as a consequence of the COVID-19 public health eme rgency (PHE) during this inspection period.
On December 31, 2021, 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 Crystal River Nuclear Plant Unit 3 (CR-3). A combination of on-site and remote inspection activities (in-office reviews) were performed as a consequence of the COVID-19 public health emergency (PHE) during this inspection period.
 
The inspector examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and the conditions of your license. The inspection consisted of observations by the inspector, interviews with site personnel, a review of procedur es and records, and plant walkdowns. The results of the inspection were discussed with you and other members of the CR-3 staff on January 6, 2022, and are described in the enclosed repo rt.
 
Based on the results of this inspection, the NRC has determined that one Severity Level IV violation of NRC requireme nts occurred. The violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2.a of the Enforcement Policy. The NCV is described in the subject inspection report. If you contest the violation or the significance of the NCV, you should provide a response within 30 days of the date of this letter, with the basis for your denial, to the Nuclear Re gulatory Commission, ATTN: Document Control Desk, Washington DC 20555-000 1.


In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter, 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/ad ams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguar ds information so that it can be made available to the Public without redaction.
The inspector examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and the conditions of your license. The inspection consisted of observations by the inspector, interviews with site personnel, a review of procedures and records, and plant walkdowns. The results of the inspection were discussed with you and other members of the CR-3 staff on January 6, 2022, and are described in the enclosed report.


Curr ent NRC re gulations and guid ance are included on the N RC's website at www.nrc.gov; select Radioactive Waste; De commissioning of Nuclear Facilities; then Regulations, Guidance and Communications. The c urrent Enforcement Policy is included on the NRC's 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 1-866-5 12-1 800. The GPO is open from 8:00 a.m. to 5:30 p.m. EST, Monday through Frid ay (except Federal holidays).
Based on the results of this inspection, the NRC has determined that one Severity Level IV violation of NRC requirements occurred. The violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2.a of the Enforcement Policy. The NCV is described in the subject inspection report. If you contest the violation or the significance of the NCV, you should provide a response within 30 days of the date of this letter, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001.


B. Reid 2
In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter, 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.


No reply to this letter is required. Please contact Katherine Warne r, at 610- 337-5389, if you have any questions regarding this matter.
Current NRC regulations and guidance are included on the NRC's 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 NRC's 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). No reply to this letter is required. Please contact Katherine Warner, at 610-337-5389, if you have any questions regarding this matter.


Sincerely, Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor HP Branch Division of Radiological Safety and Security
Sincerely, Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor HP Branch Division of Radiological Safety and Security  


Docket No. 05000 302 License No. DPR-72
Docket No.


===Enclosure:===
05000302 License No.
Inspection Report 05000302/20 2100 4 w/Attachment


REGION I==
DPR-72
INSPECTION REPORT


Report No. 05000 302/202 1004
Enclosure:
Inspection Report 05000302/2021004 w/Attachment


Docket No. 05000 302
cc w/encl:
Distribution via ListServ Anthony M.


License No. DPR-72
Dimitriadis Digitally signed by Anthony M.


Licensee: Accelerated Decommissioning Partners CR3, LLC (ADP)
Dimitriadis Date: 2022.01.24 13:13:29 -05'00'


Facility: Crystal Riv er Unit 3 (CR-3)
Enclosure


Location: Crystal River, FL 34428-6708
=EXECUTIVE SUMMARY=
Accelerated Decommissioning Partners CR3, LLC (ADP)


Inspection Dates: October 1 - December 31, 2021
Crystal River Nuclear Plant NRC Inspection Report No. 05000302/2021004


Inspector: Katherine Wa rne r, Senior Health Physicist Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Radiological Safety and Security
An announced decommissioning inspection was completed on December 31, 2021 at the permanently shutdown Crystal River Unit 3 (CR3). Certain inspection activities (in-office reviews) were conducted remotely as a consequence of the COVID-19 PHE during this inspection period. The inspection included a review of design changes and modifications, corrective actions, occupational radiation exposure, quality assurance, safety conscious work environment, decommissioning performance and status reviews, fire protection, and solid radioactive waste management and transportation of radioactive materials. The inspection consisted of observations by the inspector, interviews with site personnel, a review of procedures and records, and plant walkdowns. The NRC's program for overseeing the safe decommissioning of a shut down nuclear power reactor is described in Inspection Manual Chapter (IMC) 2561, Decommissioning Power Reactor Inspection Program.


Approved By: Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Radiological Safety and Security
One Severity Level IV non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.48(f)(1), was identified based on the licensees failure to prevent fires from occurring on-site. Specifically, the site did not properly implement FIR-0003, Control of Hot Work and Ignition Sources to maintain combustible material in the Unit 3 Sea Water Room at an adequate distance of hot work which resulted in a fire. However, because the violation was of very low safety significance and was entered into Crystal Rivers CAP (2021000123), this violation is being treated as an NCV consistent with Section 2.3.2 of the Enforcement Policy.


EXECUTIVE SUMMARY
(NCV 05000302/2021004-01, Failure to reasonably prevent fire from occurring in the auxiliary building).


Accelerated Decommissioning Partners CR3, LLC (ADP)
=REPORT DETAILS=
Crystal Riv er Nuclear Plant NRC Inspection Report No. 0500 0302/20 2100 4


An announced decommissioning inspection was completed on December 31, 2021 at the permane ntly shutdown Cry s tal Riv er Unit 3 (CR3). Certain inspection activities (in-office reviews) were conducted remotely as a consequence of the COVID-19 PHE during this inspection period. The inspection included a review of design changes and modifications, corrective actions, occupational radiation exposure, quality assurance, safety conscious work environment, decommissioning performance and status reviews, fire protection, and solid radioactive waste management and transportation of radioactive materials. The inspection consisted of observations by the inspector, interviews with site personnel, a review of procedur es and records, and plant walkdowns. The NR C's program for overseeing the safe decommissioning of a shut down nuclear powe r reactor is described in Inspection Manual Chapter (IMC ) 2561, D ecommissioning Power Reactor Inspection Program.
1.0 Background


One Severity Level IV non-cited violation (NCV) of Title 10 of the Code of Federal Re gulations (10 CFR ) 50.48(f)( 1), was identified based on the licensees failure to prevent fires from occurring on-site. Specifically, the site did not properly implement FIR-0003, Control of Hot Work and Ignition Sources to maintain combustible material in the Unit 3 Sea Water Room at an adequ ate distance of hot work which resulted in a fire. However, because the violation was of very low safety significance and was entered into Crystal Rivers CAP (20210 0012 3), this violation is being treated as an NCV consistent with Section 2.3.2 of the Enforcement Policy.
On February 20, 2013, Duke Energy sent a letter [Agency Documentation and Management System Accession Number ML13056A005] to the NRC certifying the permanent cessation of power operations and permanent removal of fuel from the reactor. This met the requirements of 10 Code of Federal Regulations (CFR)50.82(a)(1)(i) and 50.82(a)(1)(ii). On June 14, 2019, the NRC received a license transfer application [ML19170A209] and conforming amendment request filed by the Duke Energy Florida (DEF), LLC on behalf of itself and Accelerated Decommissioning Partners (ADP) CR3, LLC. The application sought NRC approval of the direct transfer of Facility Operating License No. DPR-72 for CR-3 and the general license for the CR-3 ISFSI from the current holder, DEF to ADP CR3, which is a wholly owned subsidiary of ADP, LLC, which the NRC approved on April 1, 2020 [ML20069A023]. On October 1, 2020, ADP and Duke Energy successfully completed the transaction.


(NCV 0500 0302/2 0210 04- 01, Failure to reasonably prevent fire from occurring in the auxiliary building).
CR-3 was inspected under the Actively Decommissioning (DECON), No Fuel in the Spent Fuel Pool category as described in IMC 2561 during this inspection period.


ii REPORT DET AILS
2.0 Active Decommissioning Performance and Status Review


1.0 Background
2.1 Inspection Procedures (IPs) 37801, 40801, 64704, 71801, 83750, and 86750


On Februa ry 20, 2013, Duke Energy sent a letter [Agency Documentation and Management Sy s tem Acc es s ion Number ML13056A005] to the NRC certifying the permane nt cessation of power oper ations and perman ent removal of fuel from the reactor. This met the requirements of 10 Code of Federal Re gulations (CF R)
====a. Inspection Scope====
50.82(a )(1) (i) an d 50.82(a) (1) (ii). On June 14, 2019, the NRC received a license transfer application [ML19170A209] and conforming amen dment requ est filed by the Duke Energy Florida (DEF), LLC on b ehalf of itself and Accelerated Decommissioning Partners (ADP) CR3, LLC. The application sought NRC a pproval of the direct transfer of Facility Operating License No. DPR-72 for CR-3 and the gene ral license for the CR-3 ISFSI from the current holder, DEF to ADP CR3, which is a wholly owned subsidiary of ADP, LLC, which the NRC approved on April 1, 2020 [ML20069A023]. On October 1, 2020, ADP and Duk e Energy successfully completed the transaction.
The inspector performed on-site decommissioning inspections November 29 - December 1, 2021, supplemented by in-office reviews of information supplied by ADP and periodic phone calls. The inspection consisted of observations by the inspector, interviews with site personnel, a review of procedures and records, and plant walk-downs.


CR-3 w as inspected under the Actively Decommissioning (DECON), No Fuel in the Spent Fuel Pool category as described in IMC 2561 during this inspection period.
The inspector conducted document reviews and interviews with plant personnel to determine if ADP procedures and processes were adequate and in accordance with the regulations and guidance associated with 10 CFR 50.59, and to determine if changes made by ADP under 10 CFR 50.59 required prior NRC approval.


2.0 Active D ecommissioning Performance and Status Review
The inspector 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 ADP assigned timely and appropriate prioritization for issue resolution commensurate with the significance of the issue


2.1 Inspection Procedures (I Ps ) 37801, 408 01, 6470 4, 7180 1, 83750, and 867 50
The inspector conducted walkdowns and tours of various facilities and storage areas, including the reactor and auxiliary buildings. The inspector observed select pre-job briefings and associated work activities, including work in the B decay heat vault and various work in the reactor building. The inspector also observed select management meetings.


a. Inspection Scope
The inspector reviewed documentation associated with quality assurance under the site decommissioning quality assurance program (DQAP), occupational exposure, and radioactive waste management to determine the effectiveness of site programs. The inspector interviewed radiation workers, radiation protection management and technicians, and the site quality assurance manager.


The inspector performed on-site decommissioning inspections November 29 -
The inspector reviewed documents and interviewed plant personnel to assess the licensees effectiveness of its decommissioning fire protection program and if it was maintained and implemented to address the potential for fires that could result in the release or spread of radioactive materials. The inspector performed plant walkdowns to assess field conditions and the storage of combustible materials.
December 1, 2021, supplemented by in-office reviews of information supplied by ADP and perio dic phone calls. The inspection consisted of observations by the inspector, interviews with site personnel, a review of procedures and records, and pl ant walk-downs.


The inspector conducted document reviews and interviews with plant personnel to determine if ADP procedures and processes were adequ ate and in accordance with the regulations and guid ance associated with 10 CFR 50.59, and to determine if changes made by ADP under 10 CFR 50.5 9 require d prior N RC app roval.
The inspector performed a continued follow-up inspection to review the sites continued actions and progress regarding the results of the Safety Conscious Work Environment assessment conducted in July 2021 and follow-up inspection in September 2021 (NRC Inspection Report 2021003). The inspector interviewed site personnel and reviewed the associated condition reports to determine if the site screened the condition reports per their corrective action program, identified appropriate corrective actions, and the progress on these items.


The inspector reviewed a repr esentative 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 ADP assigned timely and appropriate prio ritization for issue resolution commensurate with the significance of the iss ue
====b. Observations and Findings====
The inspector determined that 10 CFR 50.59 screenings and evaluations had been properly performed. The inspector determined that selected changes under 10 CFR 50.59 did not require prior NRC approval and safety reviews were performed for design changes and modifications in accordance with applicable regulatory requirements, license conditions and the Decommissioning Safety Analysis Report.


The inspector conducted walkdowns and tours of various facilities and storage areas, including the reactor and auxiliary buildings. The inspector observed select pre-job briefings and associated work activities, including work in the B decay heat vault and various work in the reactor building. The inspector also observed select manageme nt meetings.
The inspectors determined that issues had been identified, entered into the CAP, and evaluated commensurate with their safety significance through document reviews.


The inspector reviewed documentation associated with quality assurance under the site decommissioning quality assurance program (DQAP), occupational exposure, and radioactive waste management to determine the effectiveness of site programs. The inspector interviewed radiation wo rkers, radiation protection management and technicians, and the s it e quality assurance manager.
Several of these condition reports included radiation monitoring alarms on trucks prior to leaving the site, including one that the inspector directly observed. The inspector determined that the site implemented appropriate immediate actions to disposition and survey the contents of the truck to ensure that any radioactive material remained on-site and long-term corrective actions, including implementing a requirement for a radiation protection technician to accompany all trucks to the truck monitoring portal to ensure all appropriate surveys were complete and available for immediate response to any alarms (CRs 2021000111 and 2021000116). The inspector determined that ADP had performed activities described in the DQAP as appropriate.


The inspector reviewed documents and interviewe d plant pe rsonnel to assess the licensees effectiveness of its decommissioning fire protection program and if it was maintained and implemented to add ress the potential for fires that could result in the release or spread of radioactive materials. The inspector performed plant walkdo w ns to assess field conditions and the storage of combustible materials.
The inspector reviewed the site fire protection program as defined by Crystal River Unit3 Fire Protection Plan, Revision 38 and associated procedures and fire hazards analysis for compliance with regulatory and license requirements.


The inspector performed a continued follow-up inspection to review the sites continued actions and progress regardin g the results of the Safety Conscious Work Environment assessment conducted in July 2021 and follow -u p inspection in September 2021 (N RC Inspection Report 202100 3). The inspector interviewed site personnel and reviewed the associated condition reports to determine if the site screened the condition reports per their corrective action program, identified appro priate corrective actions, and the progr ess on these items.
The inspector assessed the sites safety conscious work environment, including review of nine condition reports and associated corrective actions generated from the results of the July and September inspections (NRC Inspection Report 2021003).


b. Observations and Findings
The inspector determined that the site generally implemented appropriate corrective actions associated with these issues, including integrating daily planning meetings to include cross-participation by the various site groups, giving situational training on when to write a condition report, and establishing a weekly CR-3 site leadership team meeting. Several actions to include discussion at quarterly meetings on the organizational effectiveness of the site amongst other topics and an evaluation of the effectiveness of the corrective action plan associated with CR2021000078 are actions either to be continued or acceptable to perform after some time has passed.


The inspector determined that 10 CFR 50.59 screenings and evaluations had been prope rly performed. The inspector determined that selected changes under 10 CFR 50.59 did not requir e prior N RC app roval and safety reviews were perform ed for design changes and modifications in accordance with applicable regulatory req uir ements, license conditions and the Decommissioning Safety Analysis Report.
The inspectors noted that the previously identified weakness in the staffs understanding of how to initiate a condition report (NRC Inspection Report 2021003 and CR2021000114) had improved. The inspector observed discussions on condition report initiation during pre-job briefs and the sampling of individuals interviewed correctly identified the process of initiating a condition report and its purpose. The inspector will continue to follow up on any potential remaining tensions caused by contractual challenges and noted that safety conscious work environment is an area of inspection that is conducted annually through implementation of Inspection Procedure 40801, Problem Identification and Resolution at Permanently Shutdown Reactors and will therefore be reviewed in calendar year 2022.


The inspectors determined that issues had been identified, entered into the CAP, and evaluated commensurate with their safety significance through d ocument reviews.
The inspector noted that during this inspection period, the site continued decommissioning and dismantlement activities in the auxiliary and turbine buildings and continued preparations for reactor vessel internals and reactor vessel segmentation. The inspector discussed ongoing active decommissioning preparations and upcoming 2022 plans with ADP staff.


Several of these condition reports included radiation monitoring ala rms on trucks prior to leaving the site, including one that the inspector directly observed. The inspector determined that the site implemented appropriate immediate actions to disposition and survey the contents of the truck to ensure that any radioactive material remained on-site and long-term corrective actions, including implementing a requirement for a radiation pr otection technician to accompany all trucks to the truck monitoring portal to ensure all approp riate surveys were complete and available for immediate response to any alarms (CRs 202100 0111 an d 2021 0001 16). The inspector determine d that ADP had perfo rmed activities described in the DQAP as appropriate.
Violation


The inspector reviewed the site fire protection program as defined by Crystal River Unit3 Fire Protection Plan, Revision 38 and associated procedures and fire hazards analysis for compliance with regulatory and license re quireme nts.
The NRC determined that one Severity Level IV non-cited violation of 10 CFR 50.48(f)(1), was identified based on the licensees failure to reasonably prevent fires from occurring. Specifically, the site did not properly implement procedure FIR-0003, Control of Hot Work and Ignition Sources to store combustible material in the Unit 3 Sea Water Room at a minimum distance of 35 feet of hot work or otherwise protected, which resulted in a fire.


The inspector assessed the sites safety conscious work environment, including review of nine condition reports and associated corrective actions generat ed from the results of the July and September inspections (NRC Inspection Report 202 1003).
On September 24, 2021, hot work was being performed by several individuals in the seawater room on the 95 elevation of the auxiliary building. A fire watch had recently left the site, so the nearby fire watch was given additional responsibility to oversee two burners performing hot work in separate areas. The fire watch noticed smoke coming from an area proximal to a concrete column out of sight. An investigation found two 5-yard disposal bags on fire. The fire was extinguished by a site employee using an ABC fire extinguisher. Upon identification, hot work was immediately suspended and the licensee entered the issue into its corrective action program as condition report 2021000123. The licensee took the following immediate corrective actions: (1)stopped hot work;
: (2) performed a housekeeping check and clean up; and (3)performed a stand-down with craft personnel to re-train and reinforce expectations on fire watch, and
: (4) modified the procedure to require the burner (hot worker) to sign the hot work permit prior to commencing work.


The inspector determined that the site generally implemented approp riate corrective
Title 10 CFR 50.48(f) requires, in part, that licensees maintain a fire protection program to address the potential for fires that could cause the release or spread of radioactive materials, including reasonably preventing these fires from occurring.


actions associated with these issues, including integrating daily planning meetings to include cross-participation by the various site groups, giving situational training on when to write a condition report, and establishing a weekly CR-3 site leadership team meeting. Several actions to include discussion at quarterly meetings on the organizational effectiveness of the site amongst other topics and an evaluation of the effectiveness of the corrective action plan associated with CR20210000 78 are actions either to be continued or acceptable to perform after some time has passed.
Crystal River Unit 3 procedure, FIR-0003, Control of Hot Work and Ignition Sources, is a quality procedure that is part of the Crystal River fire protection program used to meet 10 CFR 50.48(f)(1). FIR-0003 requires, in part, that the licensee ensure combustible material meets the required minimum distance from ignition sources.


The inspectors noted that the previously identified weakness in the staffs understandin g of how to initiate a condition report (N RC Inspection Report 2021003 and CR2 0210 0011 4) had impr oved. The inspector observed discussions on condition report initiation during pr e-job b riefs and the sampling of individuals interviewed correctly identified the process of initiating a condition report a nd its purpose. The inspector will continue to follow up on any potential remaining tensions caused by contractual challenges and noted that safety conscious work environment is an area of inspection that is conducted annually through implementation of Inspection Procedure 40801, Problem Identification and Resolution at Permanently Shutdown Re actors and will therefore be reviewed in calen dar year 2022.
Contrary to the above, the licensee failed perform required work area inspections to ensure combustible material in the Unit 3 Sea Water Room were maintained at an adequate distance of hot work, which resulted in a fire.
 
The inspector noted that during this inspection period, the site continued decommissioning and dismantlement activities in the auxiliary and turbine buildings and continued pre parations for reactor vessel internals and reactor vessel segmentation. The inspector discussed ongoing active decommissioning prepa rations and upcoming 2022 plans with ADP staff.
 
Violation
 
The NRC dete rmined that one Severity Level IV non-cited violation of 10 CFR 50.48(f)( 1), was identified based on the licensees failure to reasonably prevent fires from occurring. Specifically, the site did not properly implement procedur e FIR -0003, Control of Hot Work and Ignition Sources to store combustible material in the Unit 3 Sea Water Room at a minimum distance of 35 feet of hot work or otherwise protected, whic h resulted in a fire.
 
On September 24, 2021, hot work was being perfo rmed by several individuals in the seawater room on the 95 elevation of the auxiliary building. A fire watch had recently left the site, so the nearby fire watch was given additional responsibility to oversee two burne rs performing hot work in separate ar eas. The fire watch noticed smoke coming from an area proximal to a concrete column out of sight. An investigation found two 5-yard disposal bags on fire. The fire was extinguished by a site employee using an ABC fire extinguisher. Upon identification, hot work was immediately suspended an d the licensee entered the issue into its corrective action program as condition repo rt 20210 0012 3. The licensee took the following immediate corrective actions: (1)
stopped hot work; (2) performed a ho usekeeping check and clean up; and (3)
performed a stand-d own with craft personnel to re-train an d reinforce expe ctations on fire watch, and (4) modified the procedur e to require the burner (h ot work e r) to sign the hot work permit prior to commencing work.
 
Title 10 CFR 50.48(f) requi res, in part, that licensees maintain a fire protection progr am to address the potential for fires that could cause the release or spread of radioactive materials, including reasonably preventing these fires from occurring.
 
Crystal River Unit 3 procedure, FIR-0003, Co ntrol of Hot Work and Ignition Sources, is a quality procedure that is part of the Crystal River fire protection progr am used to meet 10 CFR 50.48(f)(1). FIR-0 003 req uires, in part, that the licensee ensure combustible material meets the required minimum distance from ignition sources.
 
Contrary to the above, the licensee failed perform requir ed work area insp ections to ensure combustible material in the Unit 3 Sea Water Room were maintain ed at an ade quate distance of hot work, whic h resulted in a fire.


This violation was determined to be a Severity Level IV violation using Section 6.3.d of the NRC Enforcement Policy, dated May 15, 2018, regarding the failure to implement procedures, which has a low safety significance as no contamination was evaluated to be released from this event.
This violation was determined to be a Severity Level IV violation using Section 6.3.d of the NRC Enforcement Policy, dated May 15, 2018, regarding the failure to implement procedures, which has a low safety significance as no contamination was evaluated to be released from this event.


Since the licensee placed the deficiency into its corrective action program (2021 0001 23), the safety significance of the issue was determined to be very low, and because the violation was not willful or repetitive, t his violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2.a of the NRC Enforcement Policy (NCV 05000302/20 210 04- 0 1, Failure to reasonably prevent fire from occurring in the auxiliary building).
Since the licensee placed the deficiency into its corrective action program (2021000123), the safety significance of the issue was determined to be very low, and because the violation was not willful or repetitive, this violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2.a of the NRC Enforcement Policy (NCV 05000302/2021004-01, Failure to reasonably prevent fire from occurring in the auxiliary building).


c. Conclusions
====c. Conclusions====
One Severity Level IV NCV of 10 CFR 50.48(f)(1) was identified based on the licensees failure to reasonably prevent fires from occurring.


One Severity Level IV NCV of 10 CFR 50.48(f)(1 ) was identified based on the licensees failure to reasonably prevent fires from occurring.
3.0  
 
3.0 Exit Meeting Summary


===Exit Meeting Summary===
On, January 6, 2022, the inspector presented the inspection results to Mr. Billy Reid, Site Vice President, and other members of the CR-3 staff. No proprietary information was retained by the inspector or documented in this report.
On, January 6, 2022, the inspector presented the inspection results to Mr. Billy Reid, Site Vice President, and other members of the CR-3 staff. No proprietary information was retained by the inspector or documented in this report.


ATTACHMENT: SUPPLEMENTAL INFORMATION
ATTACHMENT:  


SUPPLEMENTAL INFORMAT ION
=SUPPLEMENTAL INFORMATION=
 
PART IAL LI ST OF PERSONS CONT ACT ED
 
B. Reid, Site V ic e President B. Akins, Radiation Protection Manager D. Bartlett, RP Technician M. B l ak e, LTP/FSS Consultant TSSD C. Burtoff, RP Engineer T. Doruff, D&D Planner M. Erickson, LTP/FSS Consultant TSS D C. Miller, Operations and Maintenance Mana ger L. Reader, RP Specialist G. Thibodeaux, Vice President Director of Health and Safety M. Van Sicklen, Licensing Manager M. Walker, D&D Manager L. McDougal, ORANO Project Manager


SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
: [[contact::B. Reid]], Site Vice President
: [[contact::B. Akins]], Radiation Protection Manager
: [[contact::D. Bartlett]], RP Technician
: [[contact::M. Blake]], LTP/FSS Consultant TSSD
: [[contact::C. Burtoff]], RP Engineer
: [[contact::T. Doruff]], D&D Planner
: [[contact::M. Erickson]], LTP/FSS Consultant TSSD
: [[contact::C. Miller]], Operations and Maintenance Manager
: [[contact::L. Reader]], RP Specialist
: [[contact::G. Thibodeaux]], Vice President Director of Health and Safety
: [[contact::M. Van Sicklen]], Licensing Manager
: [[contact::M. Walker]], D&D Manager
: [[contact::L. McDougal]], ORANO Project Manager
ITEMS OPEN, CLOSED, AND DISCUSSED
ITEMS OPEN, CLOSED, AND DISCUSSED
None
None
PARTIAL LIST OF DOCUMENTS REVIEWED
Condition Reports
21000013
21000078
21000079
21000080
21000081
21000082
21000083
21000084
21000111
21000113
21000114
21000115
21000116
21000120
21000121
21000123
21000127
21000128
21000130
Procedures
CAP-0200, Corrective Action Program, Revision 7
HPP-202A, Radiological Surveys and Inspections, Revision 50


PART IAL LI ST OF DOCUMENT S REVIEWED
Miscellaneous
 
CFR 50.59 Screenings Various Dated September - November 2021
Condition Re ports
REG10-2020-01, License Transfer to ADP CR3, LLC, October 1, 2020
 
CR3-QAPM, Crystal River Quality Assurance Program Manual, Revision 2
20210 0001 3 20210 0007 8 20210 0007 9 20210 0008 0 20210 0008 1 20210 0008 2 20210 0008 3 20210 0008 4 20210 0011 1 20210 0011 3 20210 0011 4 20210 0011 5 20210 0011 6 20210 0012 0 20210 0012 1 20210 0012 3 20210 0012 7 20210 0012 8 20210 0013 0
Crystal River #3 Decommissioning BL November 30, 2021 Schedule
 
Crystal River Unit 3 Fire Hazards Analysis, Revision 18
Procedures CAP-0200, Cor rec tiv e A c tion Program, Revision 7 HPP-202A, Radiological Surveys and Inspections, Revision 50
Crystal River Unit 3, Fire Protection Plan, Revision 38
 
Defueled Safety Analysis Report Crystal River Unit 3, Revision 7
A-1 Miscellaneous 10 CFR 50.59 Screenings Various Dated Septembe r - November 20 21 REG10-2 020- 01, License Transfer to ADP CR3, LLC, October 1, 2020 CR3-QAPM, Crystal River Quality Assurance Program Manual, Revision 2 Crystal River #3 Decommissioning BL November 30, 2021 Schedule Crystal Riv er Unit 3 Fire Hazards Analysis, Revision 18 Crystal Riv er Unit 3, Fire Protection Plan, Revision 38 Defueled Safety Analysis Report Crystal Riv er Unit 3, Revision 7 QS-CR30 21-001, Assessment of the Effectiveness of the Implementation of License Transfer Activities, January 6, 2021 Radiologic al Surv ey s, v arious REG10-2 021-35 REG10-2 021-36 REG10-2 021-41 REG010- 2021-46
QS-CR3021-001, Assessment of the Effectiveness of the Implementation of License Transfer
 
Activities, January 6, 2021
LI ST OF ACRONYMS USED
Radiological Surveys, various
 
REG10-2021-35
ADAMS Agencywide Document and Managem ent System ADP Accelerated Decommissioning Partners CAP Corr ective A c tion Program CFR Code of Fed eral R egulations CR Condition Repo rt CR-3 Crystal Riv er Unit 3 Duk e Energy/DEF Duk e Energy Florida, Inc.
REG10-2021-36
REG10-2021-41
REG010-2021-46  


IMC Inspection Manual Chapter IP Inspection Procedure NRC U.S. Nuclear Regulatory Commission PHE Public Health Emergency PSDAR Post Shutdown Activities Report SAFSTOR Safe Storage
LIST OF ACRONYMS USED


A-2
ADAMS
Agencywide Document and Management System
ADP
Accelerated Decommissioning Partners
CAP
Corrective Action Program
CFR
Code of Federal Regulations
CR
Condition Report
CR-3
Crystal River Unit 3
Duke Energy/DEF
Duke Energy Florida, Inc.
IMC
Inspection Manual Chapter
IP
Inspection Procedure
NRC
U.S. Nuclear Regulatory Commission
PHE
Public Health Emergency
PSDAR
Post Shutdown Activities Report
SAFSTOR
Safe Storage
}}
}}

Latest revision as of 19:16, 27 November 2024

Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3 - NRC Inspection Report No. 05000302/2021004
ML22011A005
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 01/24/2022
From: Anthony Dimitriadis
Decommissioning Branch I
To: Reid B
ADP CR3
References
IR 2021004
Download: ML22011A005 (11)
v • d • e


Text

January 24, 2022

SUBJECT:

ACCELERATED DECOMMISSIONING PARTNERS (ADP) CR3, LLC, CRYSTAL RIVER UNIT 3 - NRC INSPECTION REPORT NO. 05000302/2021004

Dear Mr. Reid:

On December 31, 2021, 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 Crystal River Nuclear Plant Unit 3 (CR-3). A combination of on-site and remote inspection activities (in-office reviews) were performed as a consequence of the COVID-19 public health emergency (PHE) during this inspection period.

The inspector examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and the conditions of your license. The inspection consisted of observations by the inspector, interviews with site personnel, a review of procedures and records, and plant walkdowns. The results of the inspection were discussed with you and other members of the CR-3 staff on January 6, 2022, and are described in the enclosed report.

Based on the results of this inspection, the NRC has determined that one Severity Level IV violation of NRC requirements occurred. The violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2.a of the Enforcement Policy. The NCV is described in the subject inspection report. If you contest the violation or the significance of the NCV, you should provide a response within 30 days of the date of this letter, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001.

In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter, 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 NRC's 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 NRC's 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). No reply to this letter is required. Please contact Katherine Warner, at 610-337-5389, if you have any questions regarding this matter.

Sincerely, Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor HP Branch Division of Radiological Safety and Security

Docket No.

05000302 License No.

DPR-72

Enclosure:

Inspection Report 05000302/2021004 w/Attachment

cc w/encl:

Distribution via ListServ Anthony M.

Dimitriadis Digitally signed by Anthony M.

Dimitriadis Date: 2022.01.24 13:13:29 -05'00'

Enclosure

EXECUTIVE SUMMARY

Accelerated Decommissioning Partners CR3, LLC (ADP)

Crystal River Nuclear Plant NRC Inspection Report No. 05000302/2021004

An announced decommissioning inspection was completed on December 31, 2021 at the permanently shutdown Crystal River Unit 3 (CR3). Certain inspection activities (in-office reviews) were conducted remotely as a consequence of the COVID-19 PHE during this inspection period. The inspection included a review of design changes and modifications, corrective actions, occupational radiation exposure, quality assurance, safety conscious work environment, decommissioning performance and status reviews, fire protection, and solid radioactive waste management and transportation of radioactive materials. The inspection consisted of observations by the inspector, interviews with site personnel, a review of procedures and records, and plant walkdowns. The NRC's program for overseeing the safe decommissioning of a shut down nuclear power reactor is described in Inspection Manual Chapter (IMC) 2561, Decommissioning Power Reactor Inspection Program.

One Severity Level IV non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.48(f)(1), was identified based on the licensees failure to prevent fires from occurring on-site. Specifically, the site did not properly implement FIR-0003, Control of Hot Work and Ignition Sources to maintain combustible material in the Unit 3 Sea Water Room at an adequate distance of hot work which resulted in a fire. However, because the violation was of very low safety significance and was entered into Crystal Rivers CAP (2021000123), this violation is being treated as an NCV consistent with Section 2.3.2 of the Enforcement Policy.

(NCV 05000302/2021004-01, Failure to reasonably prevent fire from occurring in the auxiliary building).

REPORT DETAILS

1.0 Background

On February 20, 2013, Duke Energy sent a letter [Agency Documentation and Management System Accession Number ML13056A005] to the NRC certifying the permanent cessation of power operations and permanent removal of fuel from the reactor. This met the requirements of 10 Code of Federal Regulations (CFR)50.82(a)(1)(i) and 50.82(a)(1)(ii). On June 14, 2019, the NRC received a license transfer application [ML19170A209] and conforming amendment request filed by the Duke Energy Florida (DEF), LLC on behalf of itself and Accelerated Decommissioning Partners (ADP) CR3, LLC. The application sought NRC approval of the direct transfer of Facility Operating License No. DPR-72 for CR-3 and the general license for the CR-3 ISFSI from the current holder, DEF to ADP CR3, which is a wholly owned subsidiary of ADP, LLC, which the NRC approved on April 1, 2020 [ML20069A023]. On October 1, 2020, ADP and Duke Energy successfully completed the transaction.

CR-3 was inspected under the Actively Decommissioning (DECON), No Fuel in the Spent Fuel Pool category as described in IMC 2561 during this inspection period.

2.0 Active Decommissioning Performance and Status Review

2.1 Inspection Procedures (IPs) 37801, 40801, 64704, 71801, 83750, and 86750

a. Inspection Scope

The inspector performed on-site decommissioning inspections November 29 - December 1, 2021, supplemented by in-office reviews of information supplied by ADP and periodic phone calls. The inspection consisted of observations by the inspector, interviews with site personnel, a review of procedures and records, and plant walk-downs.

The inspector conducted document reviews and interviews with plant personnel to determine if ADP procedures and processes were adequate and in accordance with the regulations and guidance associated with 10 CFR 50.59, and to determine if changes made by ADP under 10 CFR 50.59 required prior NRC approval.

The inspector 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 ADP assigned timely and appropriate prioritization for issue resolution commensurate with the significance of the issue

The inspector conducted walkdowns and tours of various facilities and storage areas, including the reactor and auxiliary buildings. The inspector observed select pre-job briefings and associated work activities, including work in the B decay heat vault and various work in the reactor building. The inspector also observed select management meetings.

The inspector reviewed documentation associated with quality assurance under the site decommissioning quality assurance program (DQAP), occupational exposure, and radioactive waste management to determine the effectiveness of site programs. The inspector interviewed radiation workers, radiation protection management and technicians, and the site quality assurance manager.

The inspector reviewed documents and interviewed plant personnel to assess the licensees effectiveness of its decommissioning fire protection program and if it was maintained and implemented to address the potential for fires that could result in the release or spread of radioactive materials. The inspector performed plant walkdowns to assess field conditions and the storage of combustible materials.

The inspector performed a continued follow-up inspection to review the sites continued actions and progress regarding the results of the Safety Conscious Work Environment assessment conducted in July 2021 and follow-up inspection in September 2021 (NRC Inspection Report 2021003). The inspector interviewed site personnel and reviewed the associated condition reports to determine if the site screened the condition reports per their corrective action program, identified appropriate corrective actions, and the progress on these items.

b. Observations and Findings

The inspector determined that 10 CFR 50.59 screenings and evaluations had been properly performed. The inspector determined that selected changes under 10 CFR 50.59 did not require prior NRC approval and safety reviews were performed for design changes and modifications in accordance with applicable regulatory requirements, license conditions and the Decommissioning Safety Analysis Report.

The inspectors determined that issues had been identified, entered into the CAP, and evaluated commensurate with their safety significance through document reviews.

Several of these condition reports included radiation monitoring alarms on trucks prior to leaving the site, including one that the inspector directly observed. The inspector determined that the site implemented appropriate immediate actions to disposition and survey the contents of the truck to ensure that any radioactive material remained on-site and long-term corrective actions, including implementing a requirement for a radiation protection technician to accompany all trucks to the truck monitoring portal to ensure all appropriate surveys were complete and available for immediate response to any alarms (CRs 2021000111 and 2021000116). The inspector determined that ADP had performed activities described in the DQAP as appropriate.

The inspector reviewed the site fire protection program as defined by Crystal River Unit3 Fire Protection Plan, Revision 38 and associated procedures and fire hazards analysis for compliance with regulatory and license requirements.

The inspector assessed the sites safety conscious work environment, including review of nine condition reports and associated corrective actions generated from the results of the July and September inspections (NRC Inspection Report 2021003).

The inspector determined that the site generally implemented appropriate corrective actions associated with these issues, including integrating daily planning meetings to include cross-participation by the various site groups, giving situational training on when to write a condition report, and establishing a weekly CR-3 site leadership team meeting. Several actions to include discussion at quarterly meetings on the organizational effectiveness of the site amongst other topics and an evaluation of the effectiveness of the corrective action plan associated with CR2021000078 are actions either to be continued or acceptable to perform after some time has passed.

The inspectors noted that the previously identified weakness in the staffs understanding of how to initiate a condition report (NRC Inspection Report 2021003 and CR2021000114) had improved. The inspector observed discussions on condition report initiation during pre-job briefs and the sampling of individuals interviewed correctly identified the process of initiating a condition report and its purpose. The inspector will continue to follow up on any potential remaining tensions caused by contractual challenges and noted that safety conscious work environment is an area of inspection that is conducted annually through implementation of Inspection Procedure 40801, Problem Identification and Resolution at Permanently Shutdown Reactors and will therefore be reviewed in calendar year 2022.

The inspector noted that during this inspection period, the site continued decommissioning and dismantlement activities in the auxiliary and turbine buildings and continued preparations for reactor vessel internals and reactor vessel segmentation. The inspector discussed ongoing active decommissioning preparations and upcoming 2022 plans with ADP staff.

Violation

The NRC determined that one Severity Level IV non-cited violation of 10 CFR 50.48(f)(1), was identified based on the licensees failure to reasonably prevent fires from occurring. Specifically, the site did not properly implement procedure FIR-0003, Control of Hot Work and Ignition Sources to store combustible material in the Unit 3 Sea Water Room at a minimum distance of 35 feet of hot work or otherwise protected, which resulted in a fire.

On September 24, 2021, hot work was being performed by several individuals in the seawater room on the 95 elevation of the auxiliary building. A fire watch had recently left the site, so the nearby fire watch was given additional responsibility to oversee two burners performing hot work in separate areas. The fire watch noticed smoke coming from an area proximal to a concrete column out of sight. An investigation found two 5-yard disposal bags on fire. The fire was extinguished by a site employee using an ABC fire extinguisher. Upon identification, hot work was immediately suspended and the licensee entered the issue into its corrective action program as condition report 2021000123. The licensee took the following immediate corrective actions: (1)stopped hot work;

(2) performed a housekeeping check and clean up; and (3)performed a stand-down with craft personnel to re-train and reinforce expectations on fire watch, and
(4) modified the procedure to require the burner (hot worker) to sign the hot work permit prior to commencing work.

Title 10 CFR 50.48(f) requires, in part, that licensees maintain a fire protection program to address the potential for fires that could cause the release or spread of radioactive materials, including reasonably preventing these fires from occurring.

Crystal River Unit 3 procedure, FIR-0003, Control of Hot Work and Ignition Sources, is a quality procedure that is part of the Crystal River fire protection program used to meet 10 CFR 50.48(f)(1). FIR-0003 requires, in part, that the licensee ensure combustible material meets the required minimum distance from ignition sources.

Contrary to the above, the licensee failed perform required work area inspections to ensure combustible material in the Unit 3 Sea Water Room were maintained at an adequate distance of hot work, which resulted in a fire.

This violation was determined to be a Severity Level IV violation using Section 6.3.d of the NRC Enforcement Policy, dated May 15, 2018, regarding the failure to implement procedures, which has a low safety significance as no contamination was evaluated to be released from this event.

Since the licensee placed the deficiency into its corrective action program (2021000123), the safety significance of the issue was determined to be very low, and because the violation was not willful or repetitive, this violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2.a of the NRC Enforcement Policy (NCV 05000302/2021004-01, Failure to reasonably prevent fire from occurring in the auxiliary building).

c. Conclusions

One Severity Level IV NCV of 10 CFR 50.48(f)(1) was identified based on the licensees failure to reasonably prevent fires from occurring.

3.0

Exit Meeting Summary

On, January 6, 2022, the inspector presented the inspection results to Mr. Billy Reid, Site Vice President, and other members of the CR-3 staff. No proprietary information was retained by the inspector or documented in this report.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

B. Reid, Site Vice President
B. Akins, Radiation Protection Manager
D. Bartlett, RP Technician
M. Blake, LTP/FSS Consultant TSSD
C. Burtoff, RP Engineer
T. Doruff, D&D Planner
M. Erickson, LTP/FSS Consultant TSSD
C. Miller, Operations and Maintenance Manager
L. Reader, RP Specialist
G. Thibodeaux, Vice President Director of Health and Safety
M. Van Sicklen, Licensing Manager
M. Walker, D&D Manager
L. McDougal, ORANO Project Manager

ITEMS OPEN, CLOSED, AND DISCUSSED

None

PARTIAL LIST OF DOCUMENTS REVIEWED

Condition Reports

21000013

21000078

21000079

21000080

21000081

21000082

21000083

21000084

21000111

21000113

21000114

21000115

21000116

21000120

21000121

21000123

21000127

21000128

21000130

Procedures

CAP-0200, Corrective Action Program, Revision 7

HPP-202A, Radiological Surveys and Inspections, Revision 50

Miscellaneous

CFR 50.59 Screenings Various Dated September - November 2021

REG10-2020-01, License Transfer to ADP CR3, LLC, October 1, 2020

CR3-QAPM, Crystal River Quality Assurance Program Manual, Revision 2

Crystal River #3 Decommissioning BL November 30, 2021 Schedule

Crystal River Unit 3 Fire Hazards Analysis, Revision 18

Crystal River Unit 3, Fire Protection Plan, Revision 38

Defueled Safety Analysis Report Crystal River Unit 3, Revision 7

QS-CR3021-001, Assessment of the Effectiveness of the Implementation of License Transfer

Activities, January 6, 2021

Radiological Surveys, various

REG10-2021-35

REG10-2021-36

REG10-2021-41

REG010-2021-46

LIST OF ACRONYMS USED

ADAMS

Agencywide Document and Management System

ADP

Accelerated Decommissioning Partners

CAP

Corrective Action Program

CFR

Code of Federal Regulations

CR

Condition Report

CR-3

Crystal River Unit 3

Duke Energy/DEF

Duke Energy Florida, Inc.

IMC

Inspection Manual Chapter

IP

Inspection Procedure

NRC

U.S. Nuclear Regulatory Commission

PHE

Public Health Emergency

PSDAR

Post Shutdown Activities Report

SAFSTOR

Safe Storage

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