IR 05000010/2022001

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NRC Inspection Report No. 05000010/2022001(DNMS) - Dresden Nuclear Power Station, Unit 1
ML22216A028
Person / Time
Site: Dresden Constellation icon.png
Issue date: 08/08/2022
From: Rhex Edwards, Dave Hills
NRC/RGN-III/DNMS/MCID
To: Rhoades D
Constellation Energy Generation
Edwards R
References
IR 2022001
Download: ML22216A028 (15)


Text

August 8, 2022

SUBJECT:

NRC INSPECTION REPORT NO. 05000010/2022001(DNMS) - DRESDEN NUCLEAR POWER STATION, UNIT 1

Dear Mr. Rhoades:

On July 13, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed onsite inspection activities in July 2022, at the permanently shut-down Dresden Nuclear Power Station in Morris, Illinois. 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 Ms. C. Joseph and other members of your staff on July 15, 2022.

During the inspection period, the NRC inspectors reviewed the following aspects of onsite activities: safety reviews, design changes and modifications; problem identification and resolution; fire protection; decommissioning performance; occupational radiation exposure; radiological surveys; radioactive waste treatment, effluent, and environmental monitoring; and waste management and transportation. 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, reviewing work activities and interviews with personnel.

Based on the results of this inspection, the NRC did not identify any violations. This letter, its enclosure, and your response (if any) 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 Title 10 of the Code of Federal Regulations (CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Signed by Hills, David on 08/08/22 David E. Hills, Chief Materials Control, ISFSI, and Decommissioning Branch Division of Nuclear Materials Safety Docket No: 50-010 License No: DPR-2 Enclosure:

IR Nos. 05000010/2022001(DNMS)

cc w/encl: Distribution via LISTSERV

EXECUTIVE SUMMARY

Dresden Nuclear Power Station, Unit 1

NRC Inspection Report No. 05000010/2022001(DNMS)

The Dresden Nuclear Power Station is a permanently shut-down and defueled power reactor maintained in a Safe Storage (SAFSTOR) condition. This periodic safety inspection reviewed licensed activities associated with safety reviews, design changes and modifications; self-assessments, audits, and corrective actions; fire protection; decommissioning performance; occupational radiation exposure; radiological surveys; radioactive waste treatment, effluent, and environmental monitoring; and waste management and transportation.

Safety Reviews, Design Changes, and Modifications The licensee performed adequate safety evaluations or screenings, completed design change evaluations, and properly assessed decommissioning impacts of various work activities as required by Title 10 of the Code of Federal Regulations (CFR) 50.59 and its safety review process.

Problem Identification and Resolution 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.

Fire Protection Program An effective decommissioning Fire Protection Program was maintained and implemented that reasonably prevented fires; provided the capability to rapidly detect, control, and extinguish fires that could result in radiological hazards; and ensured the risk of fire-induced hazards to the public, environment, and plant personnel were minimized.

Decommissioning Performance and Status Review The inspectors determined that decommissioning activities were in accordance with the regulations and license requirements. Decommissioning staffing, qualifications, and training were appropriate to the requirements and current decommissioning status. The material condition of structures, systems, and components supported the SAFSTOR condition of the facility.

Occupational Radiation Exposure Adequate protection of worker health and safety from exposure to radiation and radioactive material was provided. Decommissioning activities were executed in general alignment with planning documents and as provided in Radiation Work Permits (RWPs)and As Low As Is Reasonably Achievable (ALARA) reviews. Radiation surveys were performed adequately to identify the hazards present. Command and control of radiologically significant activities was executed in a manner that was safe and achieved the desired result.

Radioactive Waste Treatment, and Effluent and Environmental Monitoring There were no changes or anomalous results identified in annual effluent and environmental monitoring reports associated with Unit 1 activities.

Solid Radioactive Waste Management and Transportation of Radioactive Materials The licensee effectively processed, handled, stored, and transported radioactive material.

REPORT DETAILS

Summary of Plant Activities During this inspection period, the licensee maintained Dresden Unit 1 in SAFSTOR conditions and no major decommissioning activities occurred. Licensees activities primarily involved routine surveillance and maintenance to support continued SAFSTOR dormancy.

1.0 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors (IP 37801)1.1 Inspection Scope The inspectors performed walkdowns, reviewed documents, and interviewed plant personnel to assess the licensees performance in the following areas:

Whether the licensees safety review process and procedures identified potential changes to Technical Specification resulting from proposed changes, tests, experiments, or modifications; Changes to design basis documentation were updated consistent with design changes; Design changes or modifications were effectively evaluated to maintain safety; and Maintenance and/or work activities appropriately considered whether the activity resulted in a change or modification and were assessed in accordance with 10 CFR 50.59.

The remaining aspects of this program are inspected by the NRC through the Reactor Oversight Process (ROP) for Units 2 and 3. The inspectors verified that when issues were identified, licensee personnel appropriately documented the issue in the CAP.

1.2 Observations and Findings During this inspection period, there were no changes to the decommissioning facility that required an evaluation according to the provisions of 10 CFR 50.59. Additionally, during walkdowns of the facility on July 12 and 13, 2022, the inspectors confirmed there were no changes to Unit 1 since the last inspection in October 2021. Per licensee submittal RS-22-082, dated June 22, 2022 (ML22173A129), there were no changes to the Unit 1 Decommissioning Safety Analysis Report (DSAR) between June 22, 2020, and June 22, 2022.

No findings were identified.

1.3 Conclusions The licensee performed adequate safety evaluations or screenings, completed design change evaluations, and properly assessed decommissioning impacts of various work activities as required by 10 CFR 50.59 and its safety review process.

2.0 Problem Identification and Resolution at Permanently Shutdown Reactors (IP 40801)2.1 Inspection Scope The inspectors performed walkdowns, reviewed documents, and interviewed plant personnel to assess the licensees performance in the following areas:

Effectiveness at preventing, detecting, and correcting issues; Identifying and evaluating potential 10 CFR Part 21, Reporting of Defects and Non-Compliance Issues; Audits and assessments evaluating the CAP and Quality Assurance Program; and The licensees safety culture The remaining aspects of this program are inspected by the NRC through the ROP for Units 2 and 3.

2.2 Observations and Findings The inspectors reviewed all Unit 1 issues entered into the licensees CAP since the last inspection, and four were selected for additional follow-up. The inspectors specifically tracked work plans to address items identified during the last structural inspections performed in 2020. The other items selected for additional follow-up were independently assessed by the decommissioning inspectors or the site Resident Inspectors. The issues reviewed were found to be appropriately addressed by the licensee. There were no issues requiring reporting under 10 CFR Part 21. There were no audits performed since completion of the last NRC inspection in October 2021. The inspectors interviewed station personnel during walkdowns and did not encounter any concerns with safety culture.

No findings were identified.

2.3 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.

3.0 Fire Protection Program at Permanently Shutdown Reactors (IP 64704)3.1 Inspection Scope The inspectors performed walkdowns, reviewed documents, and interviewed plant personnel to assess the licensees performance in the following areas:

Fire protection program met Technical Specifications, Post Shutdown Decommissioning Activities Report (PSDAR), and fire hazard analyses requirements; Changes to the Fire Protection Program did not reduce the effectiveness of the program; Assessments were being performed in accordance with 10 CFR 50.48(f)(2);

Fire barriers were effectively maintained; and Administrative controls were in place to minimize the occurrence of a fire.

The inspectors verified that when issues were identified, licensee personnel appropriately documented the issue in the CAP.

3.2 Observations and Findings The inspectors performed walkdowns on July 12 and 13, 2022, to assess the Fire Protection Program as it relates to Unit 1. Specifically, the inspectors performed a general tour on July 12 of the Unit 1 facilities. On July 13, the inspectors focused on ensuring the firefighting equipment and hazards in the Unit 1 Turbine Building and the Unit 1 Interim Rad Waste Storage Facility was as described in the pre-fire plans for these areas. During walkdowns of the Unit 1 Turbine Building, the inspectors assessed the fire protection barriers between Unit 1 and Unit 2 and did not find any impairments.

There were no fire protection assessments performed since the last inspection in October 2021.

No findings were identified.

3.3 Conclusions An effective decommissioning Fire Protection Program was maintained and implemented that reasonably prevented fires; provided the capability to rapidly detect, control, and extinguish fires that could result in radiological hazards; and ensured the risk of fire-induced hazards to the public, environment, and plant personnel were minimized.

4.0 Decommissioning Performance and Status Review (IP 71801)4.1 Inspection Scope The inspectors performed walkdowns, reviewed documents, and interviewed plant personnel to assess the licensees performance in the following areas:

Whether maintenance was conducted at an appropriate frequency; Updates to the DSAR were made consistent with 10 CFR 50.71 Records important to decommissioning were kept consistent with 10 CFR 50.75(g)

Appropriate administrative and/or engineering controls were identified and implemented in work plans; Organization and staffing were appropriately adjusted for changes in the status of decommissioning; and Changes to the decommissioning schedule or costs were made consistent with the requirements in 10 CFR 50.82(a)(7).

The remaining aspects of this program are inspected by the NRC through the ROP for Units 2 and 3. The inspectors verified that when issues were identified, licensee personnel appropriately documented the issue in the CAP.

4.2 Observations and Findings Aside from radiological surveys, there was no maintenance or work performed in Unit 1 since the last inspection. Per licensee submittal RS-22-082, dated June 22, 2022 (ML22173A129), there were no changes to the Unit 1 DSAR between June 22, 2020, and June 22, 2022, which was confirmed during onsite tours on July 12 and 13, 2022.

There were no new 50.75(g) entries made since the last inspection. The inspectors reviewed engineering department training material used to familiarize the licensee staff on the remaining Unit 1 systems, and how they potentially interface with Unit 2 and 3.

During the inspection, the inspectors met with licensee management and staff including a new Project Manager overseeing future Unit 1 activities. The inspectors compared the planned expenditures from the PSDAR against the actual expenses reported in the annual radiological decommissioning funding status report, dated March 23, 2022 (ML22082A227), and noted actual expenses were less than predicted. The actual expenses appeared consistent with the SAFSTOR status of the facility. There were no changes identified to the licensees financial allocation control process that assigns expenses to the radiological decommissioning trust fund.

No findings were identified.

4.3 Conclusions The inspectors determined that decommissioning activities were in accordance with the regulations and license requirements. Decommissioning staffing, qualifications, and training were appropriate to the requirements and current decommissioning status. The material condition of structures, systems and components supported the SAFSTOR condition of the facility.

5.0 Occupational Radiation Exposure at Permanently Shutdown Reactors (IP 83750)5.1 Inspection Scope The inspectors performed walkdowns, reviewed documents, and interviewed plant personnel to assess the licensees performance in the following areas:

Changes made to organization, personnel, facilities, instrumentation, equipment, and programs that impact occupational radiation protection; Radiological controls, postings, and material conditions inside the radiological control area; Contamination monitoring including release of radioactive materials from controlled areas; Accuracy and functionality of radiation monitoring instruments; Area radiation monitors and continuous air monitors were appropriately positioned; Temporary ventilation systems were correctly configured; The remaining aspects of this program are inspected by the NRC through the ROP for Units 2 and 3. The inspectors verified that when issues were identified, licensee personnel appropriately documented the issue in the CAP.

5.2 Observations and Findings The inspectors performed walkdowns of Unit 1 on July 12 and 13, 2022. The inspectors found adequate measure were established in the Unit 1 reactor building to reasonably prevent the creation of airborne hazards; control the spread of contamination; and to reduce external dose. There were no changes in the licensees radiation protection program as it relates to Unit 1 since the last inspection. A review of selected radiological surveys did not identify any unusual radiological conditions. During tours of Unit 1, radiological postings and barriers were found to be in good condition and located where required given the radiological conditions. During a tour on July 13, a portable air sampler in the Unit 1 Turbine building was inspected and noted to be appropriately placed and within its required calibration frequency. Individuals exiting the Unit 1 controlled area were observed and used survey techniques consistent with standard industry practice.

No findings were identified.

5.3 Conclusions Adequate protection of worker health and safety from exposure to radiation and radioactive material was provided. 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.

Command and control of radiologically significant activities was executed in a manner that was safe and achieved the desired result.

6.0 Radioactive Waste Treatment, and Effluent and Environmental Monitoring (IP 84750)6.1 Inspection Scope The inspectors performed walkdowns, reviewed documents, and interviewed plant personnel to assess the licensees performance in the following areas:

Changes made to the Offsite Dose Calculations Manual or liquid, gaseous, and solid radwaste system design and operation were within the licensing basis and regulations; The annual effluent release report was submitted as required, and any anomalous results, unexpected trends, or abnormal releases were identified and entered into the CAP; Whether potential leakage or spills were appropriately added to records as required by 10 CFR 50.75(g);

The licensees annual radiological environmental monitoring report was submitted as required, and any anomalous results, unexpected trends, or abnormal environmental impacts were identified; and Changes made to the environmental program.

The inspectors verified that when issues were identified, licensee personnel appropriately documented the issue in the CAP.

6.2 Observations and Findings There were no changes with respect to Unit 1 liquid or gaseous effluent pathways or monitoring during this inspection period. The inspector noted during a review of past annual radiological effluent release and environmental monitoring reports that no anomalous results, unexpected trends, or abnormal releases were identified in association with Unit 1 activities. Since the last inspection, there were no spills or leakage associated with Unit 1 activities requiring records to be maintained in accordance with 10 CFR 50.75(g).

No findings were identified.

6.3 Conclusions There were no changes or anomalous results identified in annual effluent and environmental monitoring reports associated with Unit 1 activities.

7.0 Solid Radioactive Waste Management and Transportation of Radioactive Materials (IP 86750)7.1 Inspection Scope The inspectors performed walkdowns, reviewed documents, and interviewed plant personnel to assess the licensees performance in the following areas:

Radioactive waste storage areas were appropriately controlled, labelled, posted and secured against unauthorized removal; and Containers of radioactive material were inventoried, and their material condition was monitored.

The remaining aspects of this program are inspected by the NRC through the ROP for Units 2 and 3. The inspectors verified that when issues were identified, licensee personnel appropriately documented the issue in the CAP.

7.2 Observations and Findings During a facility tour on July 12, the inspectors found that radioactive material contained in Unit 1 was controlled in accordance with requirements. The inspectors interviewed plant personnel on July 13 and determined that no shipments of radioactive material from Unit 1 were made since the last inspection. While performing fire protection inspections of the Unit 1 Interim Radwaste Storage Facility, the inspectors observed the loading of a liner containing resins from the operating units into a shipping overpack.

No findings were identified.

7.3 Conclusions The licensee effectively processed, handled, stored, and transported radioactive material.

8.0 Exit Meeting The inspectors presented the results of the inspection to Ms. C. Joseph and other members of the Dresden Nuclear Power Station, Unit 1, staff at an exit meeting on July 15, 2022. 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

J. Bohac, Project Manager
D. Walker, Performance Specialist
D. Avery, Regulatory Assurance

INSPECTION PROCEDURES (IPs) USED

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

Reactors

IP 40801 Problem Identification and Resolution at Permanently Shutdown Reactors

IP 64704 Fire Protection Program at Permanently Shutdown Reactors

IP 71801 Decommissioning Performance and Status Reviews at Permanently

Shutdown Plants

IP 83750 Occupational Radiation Exposure

IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring

IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive

Materials

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened Type Summary

None

Closed 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 inspectors 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.

- AR 04453168; U1 2020 Structural Inspection Final Report - WR Needed; 01/20/2021

- AR 04453374; Fuel Leak When Running U1 DFP Transfer Pump; 10/16/2021

- AR 04454661; U1 TB Discrepancies; 10/21/2021

- AR 04480226; Leak on Fire Valve 1-4199-125 in U1 Condensate Pump Room; 02/23/2022

- Radiological Survey No. 2021-111267; U1 Sphere 488; 11/14/2021

- Pre-Fire Plan 252 U1 IRSF; Unit 1 IRSF; Revision 2

- Pre-Fire Plan 205 U1 TB; Unit 1 Main Turbine Floor Elev. 561, 551; Revision 2

- N-N12UNIT1; Dresden Unit 1 Training; Revision 3

- DAR-2019-01; Unit 1 Main Turbine Floor and Unit 1 Fuel Building

- DTS 0010-01; Integrity Surveillance for Unit 1 Structures; Revision 7

- Dresden Triennial Fire Protection Inspection Prepatory Self-Assessment; 10/20/2016

- DRE Fire Protection Gap Self-Assessment; 06/08/2021

- PI-AA-120; Issue Identification and Screening Process; Revision 11

- Vol. 1.6 - Fire Hazards Analysis Unit 1; Amendment 13

LIST OF ACRONYMS USED

ALARA As Low As Is Reasonably Achievable

CAP Corrective Action Program

CFR Code of Federal Regulations

DNMS Division of Nuclear Materials Safety

NRC U.S. Nuclear Regulatory Commission

PSDAR Post Shutdown Activities Report

RWP Radiation Work Permit

SAFSTOR Safe Storage

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