IR 05000010/2017012
| ML17291A949 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 10/18/2017 |
| From: | Michael Kunowski NRC/RGN-III/DNMS/MCID |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2017012 | |
| Download: ML17291A949 (14) | |
Text
October 18, 2017
SUBJECT:
DRESDEN NUCLEAR POWER STATION, UNIT 1NRC INSPECTION REPORT 05000010/2017012(DNMS)
Dear Mr. Hanson:
On October 12, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed onsite inspection activities at the permanently shut down Dresden Nuclear Power Station, Unit 1. The purpose of the inspection was to determine whether decommissioning activities were conducted safely and in accordance with NRC requirements. The enclosed report presents the results of this inspection, which were discussed with Mr. B. Franzen and other members of your staff on October 12, 2017.
During the inspection, the NRC inspector reviewed the following aspects of onsite activities:
organization, management, and cost control at the site; safety reviews, design changes, and modifications; self-assessments, audits, and corrective actions; occupational radiation exposure; radioactive waste treatment and effluent and environmental monitoring; and transportation of radioactive material. The inspection consisted of an examination of activities at the site as they relate to safety and compliance with the Commissions rules and regulations.
Areas examined during the inspection are identified in the enclosed report. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observation of work activities, and interviews with personnel.
Based on the results of this inspection, no violations of NRC requirements were identified. This letter and its enclosure will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Michael A. Kunowski, Chief Materials Control, ISFSI, and Decommissioning Branch Division of Nuclear Materials Safety
Docket No: 50-010 License No: DPR-2
Enclosure:
IR No. 05000010/2017012(DNMS)
cc: Distribution via LISTSERV
EXECUTIVE SUMMARY
Dresden Nuclear Power Station, Unit 1
NRC Inspection Report 05000010/2017012
The Dresden Nuclear Power Station Unit 1 is a permanently shut down and defueled power reactor that has been maintained in a safe storage condition (SAFSTOR). Decommissioning activities occur periodically and as warranted by radiological, material, or structural conditions.
This safety inspection reviewed the overall effectiveness of the licensees programs for continued SAFSTOR of Unit 1.
Organization, Management and Cost Controls
- The licensee adequately implemented organization, management, and cost controls in accordance with regulatory requirements, license conditions, and the Technical Specifications (TSs). (Section 1.0)
Safety Reviews, Design Changes, and Modifications
- The licensees processes were adequate to perform appropriate safety evaluations or screenings; design change evaluations; and assessments of decommissioning impacts of various work activities as required by 10 CFR Code of Federal Regulations (CFR) 50.59.
(Section 2.0)
Self-Assessment, Auditing, and Corrective Action
- Issues were identified by the licensee at appropriate thresholds and entered into the corrective action program (CAP). Issues were screened and prioritized commensurate with safety significance. Licensee evaluations determined the significance of issues, and included appropriate remedial corrective actions. (Section 3.0)
Occupational Radiation Exposure
- Workers adhered to the radiological controls provided in Radiation Work Permits (RWPs)and As Low As Is Reasonably Achievable (ALARA) plans, and followed the Radiation Protection (RP) staff instruction. Decommissioning activities were executed in general alignment with planning documents and as provided in RWPs and ALARA reviews.
Radiation surveys were performed adequately to identify the hazards present. The remaining aspects of this program are inspected by the U.S. Nuclear Regulatory Commission (NRC) through the Reactor Oversight Process (ROP) for Units 2 and 3.
(Section 4.0)
Radioactive Waste Treatment, and Effluent and Environmental Monitoring
- The licensee maintained effluent and environmental monitoring as required. With respect to Unit 1, Annual Radioactive Effluent Reports were timely submitted and satisfied Offsite Dose Calculation Manual (ODCM) requirements. The remaining aspects of this program are inspected by the NRC through the ROP for Units 2 and 3. (Section 5.0)
Solid Radioactive Waste Management and Transportation of Radioactive Materials
- The licensee maintained and shipped radioactive material in accordance with NRC and Department of Transportation regulations during the safe storage of Unit 1. The remaining aspects of this program are inspected by the NRC through the ROP for Units 2 and 3.
(Section 6.0)
REPORT DETAILS
Summary of Plant Activities
During the inspection period, the licensee maintained Dresden Unit 1 in SAFSTOR. Licensees activities primarily involved routine surveillance and maintenance to support continued SAFSTOR dormancy.
1.0 Organization, Management, and Cost Controls at Permanently Shutdown Reactors (Inspection Procedure (IP) 36801)
1.1 Inspection Scope
The inspector reviewed documents and interviewed plant personnel to assess the licensees performance as it related to the following areas:
- Implementation of CAP procedures;
- Regulatory requirements were properly implemented with respect to the site organization, staffing, and staff qualifications;
- Future licensee plans for decommissioning organization and staffing would continue to meet regulatory requirements;
- Licensee appropriately implemented TS, Technical Requirements Manual, Post-Shutdown Decommissioning Activities Report (PSDAR), and fire protection plan requirements and commitments;
- Licensee continued implementation of regulatory requirements that remained applicable as described in NRC Bulletins, Generic Letters, and Orders; and
- Licensee decommissioning activities were initiated, sequenced, and performed in a manner consistent with the PSDAR.
As part of the inspection, the inspector verified that licensee programs and procedures were appropriately implemented by licensee staff. In addition, the inspector verified that when issues were identified, licensee personnel appropriately documented the issues in the CAP.
1.2 Observations and Findings
The inspector determined through direct licensee observation, reviews of established licensee programs and procedures, corrective action documents, and interviews with licensee personnel that the appropriate regulatory requirements and commitments were followed. During walkdowns, the inspector concluded that the licensee maintained good housekeeping practices in Unit 1 and adhered to fire protection program requirements.
No findings were identified.
1.3 Conclusions
The licensee adequately implemented organization, management, and cost controls in accordance with regulatory requirements, license conditions, and the TSs.
2.0 Safety Reviews, Design Changes, and Modifications (IP 37801)
2.1 Inspection Scope
The inspector reviewed documents and interviewed plant personnel to assess the licensees performance as it related to the following areas:
- Determination that licensee procedures and processes conform to 10 CFR 50.59 and associated guidance;
- Procedures that control and implement design changes and modifications to assess that the procedures provided adequate guidance for implementation, review, and approval;
- Verification that the design change process followed approved procedures and applicable changes were effectively implemented in the field and in plant procedures, drawings, and training programs, if applicable;
- Verification that changes to preventive maintenance, corrective maintenance, and operational procedures for required equipment were implemented in accordance with the licensees processes and procedures.
The inspector verified that when issues were identified licensee personnel appropriately documented the issues in the CAP.
2.2 Observations and Findings
The inspector reviewed the licensees programs for changes. The licensee did not perform any changes to the facility that required a screening according to the provision of 10 CFR 50.59 since the last NRC inspection.
No findings were identified.
2.3 Conclusions
The licensees processes were adequate to perform appropriate safety evaluations or screenings, design change evaluations, and assessments of decommissioning impacts of various work activities as required by 10 CFR 50.59.
3.0 Self-Assessments, Audits, and Corrective Actions (IP 40801)
3.1 Inspection Scope
The inspector conducted document reviews and interviews with plant personnel to assess the licensees performance as it related to the following areas:
- Administrative procedures prescribed actions for the identification, evaluation, and resolution of problems;
- License procedures prescribed thresholds for the performance of self-assessments, audits, and surveillances;
- Licensee management reviewed self-assessments, audits, and corrective actions to remain knowledgeable of plant performance;
- Self-assessments were conducted with technically qualified personnel and sufficient independence from the licensee;
- Issues or problems were identified and corrected in accordance with the licensees CAP; and
- Quality assurance personnel audited changes in the status of decommissioning and licensee organization.
The inspector reviewed CAP documents to determine if a sufficiently low threshold for problem identification existed; the quality of follow-up evaluations, including extent-of-condition; and if the licensee assigned timely and appropriate prioritization for issue resolution commensurate with the significance of the issue.
3.2 Observations and Findings
The inspector determined that issues were identified by the licensee at an appropriate threshold within various functional areas of the site and entered into the CAP. Issues were effectively screened, prioritized, and evaluated commensurate with safety significance. The scope and depth of evaluations were adequate in that the evaluations reviewed addressed the significance of issues and assigned an appropriate course of remedial action.
No findings were identified.
3.3 Conclusions
Issues were identified by the licensee at appropriate thresholds and entered into the CAP. Issues were screened and prioritized commensurate with safety significance.
Licensee evaluations determined the significance of issues and included appropriate remedial corrective actions.
4.0 Occupational Radiation Exposure (IP 83750)
4.1 Inspection Scope
The inspector reviewed documents, made observations, and interviewed plant personnel to assess whether the licensees:
- Management and administrative controls of external radiation exposure met requirements and were designed to keep exposures ALARA;
- Processes or engineering controls were used to the extent practicable to limit concentrations of airborne radioactive materials;
- Survey and monitoring activities were performed as required;
- Control of radioactive materials and contamination met requirements;
- ALARA program was effectively implemented;
- Initiatives to implement operational methods and practices maintained doses ALARA; and
- Issues, events, or problems were identified and resolved, so as to help prevent future problems in the area of radiological controls.
The inspector verified that when issues were identified, licensee personnel appropriately documented the issues in the CAP.
4.2 Observations and Findings
The inspector found that radiological activities were evaluated by the licensee and ALARA controls were prescribed to satisfy the requirements of 10 CFR 20.1101.
Measures were established in the Unit 1 containment building to adequately prevent the creation of airborne hazards; control the spread of contamination; and to reduce external dose. A review of selected radiological surveys did not identify any unusual radiological conditions.
Occupational radiation exposure is controlled by the licensee under the same program as the operating units, Units 2 and 3. Similarly, the NRC inspects this program through the NRCs ROP for Units 2 and 3. As such, the NRC uses the ROP to provide oversight of the occupational radiation exposure program.
No findings were identified.
4.3 Conclusions
Workers adhered to the radiological controls provided in RWPs and ALARA plans, and followed RP staff instruction. Decommissioning activities were executed in general alignment with planning documents and as provided in RWPs and ALARA reviews.
Radiation surveys were performed adequately to identify the hazards present. The remaining aspects of this program are inspected by the NRC through the ROP for Units 2 and 3.
5.0 Radioactive Waste Treatment, and Effluent and Environmental Monitoring (IP 84750)
5.1 Inspection Scope
The inspector conducted document reviews and interviews with plant personnel to assess the licensees performance as it related to the following areas:
- Radioactive waste treatment systems were maintained and operated to keep offsite doses ALARA;
- The licensee effectively controlled, monitored, and quantified releases of radioactive materials in liquid, gaseous, and particulate forms to the environment; and
- The radiological environmental monitoring programs were effectively implemented to ensure effluent releases were being adequately performed as required to minimize public dose.
As part of the inspection, the inspector verified that licensee programs and procedures were appropriately implemented by licensee staff. In addition, the inspector verified that when issues were identified licensee personnel appropriately documented the issues in the corrective action program and adequate corrective actions were taken.
5.2 Observations and Findings
The inspector noted that during a review of past Annual Radiological Effluent Release Reports, no anomalous results, unexpected trends, or abnormal releases were identified in association with Unit 1 activities.
Effluent and environmental monitoring is controlled by the licensee under the same program as the operating units, Units 2 and 3. Similarly, the NRC inspects this program through the NRCs ROP for Units 2 and 3. As such, the NRC performs inspections through the ROP to provide oversight of the effluent and environmental monitoring program.
No findings were identified.
5.3 Conclusions
The licensee maintained effluent and environmental monitoring and control systems as required. With respect to Unit 1, Annual Radioactive Effluent Reports were timely submitted and satisfied ODCM requirements. The remaining aspects of this program are inspected by the NRC through the ROP for Units 2 and 3.
6.0 Solid Radioactive Waste Management and Transportation of Radioactive Materials (IP 86750)
6.1 Inspection Scope
The inspector reviewed documents and interviewed plant personnel to determine whether radioactive material is properly processed, packaged, and shipped by the licensee in accordance with NRC and Department of Transportation regulations.
6.2 Observations and Findings
Prior to the inspection, the licensee made two radioactive material shipments in 2017 from Unit 1. The inspector reviewed the required documentation associated with the shipment of dry active waste from Unit 1.
The storage and transportation of radioactive materials is controlled by the licensee under the same program as the operating units, Units 2 and 3. Similarly, the NRC inspects this program through the NRCs ROP for Units 2 and 3. As such, the NRC uses the ROP to provide oversite of the management and transportation of radioactive waste.
No findings were identified.
6.3 Conclusions
The licensee maintained and shipped radioactive material in accordance with NRC and Department of Transportation regulations during the safe storage of Unit 1. The remaining aspects of this program are inspected by the NRC through the ROP for Units 2 and 3.
7.0 Exit Meeting
The inspector presented the results of the inspection to Mr. B. Franzen and other members of the licensee staff at an onsite exit meeting on October 12, 2017. The licensee acknowledged the results presented and did not identify any of the information discussed as proprietary.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
- D. Walker, Senior Regulatory Specialist
- M. Mason, Unit 1 Senior Project Manager
INSPECTION PROCEDURES (IPs) USED
Organization and Management Controls at Permanently Shutdown Reactors
Safety Reviews, Design Changes, and Modifications at Permanently
Shutdown Reactors
Self-Assessment, Auditing and Corrective Action at Permanently Shutdown
Reactors
Radioactive Waste Treatment, and Effluent and Environmental Monitoring
Solid Radioactive Waste Management and Transportation of Radioactive
Materials
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
Type
Summary
None
Closed
Type
Summary
None
Discussed
Type
Summary
None
PARTIAL LIST OF DOCUMENTS REVIEWED
The following is a partial list of documents reviewed during the inspection. Inclusion on this list
does not imply that the NRC inspector reviewed the documents in their entirety, but rather that
selected sections of portions of the documents were evaluated as part of the overall inspection
effort. Inclusion of a document on this list does not imply NRC acceptance of the document or
any part of it, unless this is stated in the body of the inspection report.
-
2015 Unit 1 Dresden Structural Inspection Report; January 8, 2016
-
2017 Dresden Unit 1 Radiological Surveys
-
2017 Unit 1 Condition Reports
-
Changes to Post-Shutdown Decommissioning Activities Report; August 23, 2001
-
Defueled Safety Analysis Report Update; June 20, 2016
-
DFPS 4114-04; Fire Extinguisher Annual Inspection; Revision 60
-
DFPS 4114-05; Fire Extinguisher Inspections; Revision 49
-
Dresden Nuclear Power Station Corrected 2016 Radioactive Effluent Report; August 29,
2017
-
NOSA-DRE-15-11; Decommissioned Units Audit Report; December 16, 2015
-
NRC Form 540 & 541; Shipment ID No. DW-17-026; May 25, 2017
-
NRC Form 540 & 541; Shipment ID No. DW-17-051; August 31, 2017
-
Unit 1 5-Year Structural Inspection Work Down Curve; October 12, 2017
-
Unit 1 Engineering Letter 16-001; March 28, 2016
-
Unit 1 Engineering Letter 16-002; March 28, 2016
-
Unit 1 Post-Shutdown Decommissioning Activities Report; June 1, 1998
-
Update to Dresden Nuclear Power Station Unit 1 Post-Shutdown Decommissioning
Activities Report; January 5, 2007
-
WO 01960012; Unit 1 Annual PM System Ground Water Intrusion Monitoring;
September 13, 2017
LIST OF ACRONYMS USED
Agencywide Documents Access and Management System
As Low As Is Reasonably Achievable
Corrective Action Program
CFR
Code of Federal Regulations
Division of Nuclear Materials Safety
IP
Inspection Procedure
NRC
U.S. Nuclear Regulatory Commission
Offsite Dose Calculation Manual
Publicly Available Records System
Post-Shutdown Decommissioning Activities Report
Reactor Oversight Process
Radiation Protection
Radiation Work Permit
SAFSTOR
Safe Storage
TS
Technical Specification