IR 05000219/2019003

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NRC Inspection Report No. 05000219/2019003, Holtec Decommissioning International, LLC, Oyster Creek Nuclear Generating Station, Forked River, New Jersey
ML19301A812
Person / Time
Site: Oyster Creek
Issue date: 10/28/2019
From: Anthony Dimitriadis
Division of Nuclear Materials Safety I
To: Cowan P
Holtec Decommissioning International
References
IR 2019003
Download: ML19301A812 (13)


Text

B. Hanson UNITED STATES ber 28, 2019

SUBJECT:

NRC INSPECTION REPORT NO. 05000219/2019003, HOLTEC DECOMMISSIONING INTERNATIONAL, LLC, OYSTER CREEK NUCLEAR GENERATING STATION, FORKED RIVER, NEW JERSEY

Dear Ms. Cowan:

On September 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed its quarterly inspection under Inspection Manual Chapter 2561, Decommissioning Power Reactor Inspection Program, at the permanently shut down Oyster Creek Nuclear Generating Station (Oyster Creek). On-site inspections were performed August 12-14, 2019, August 19-22, 2019, and August 29, 2019. In-office reviews of information supplied by Holtec Decommissioning International, LLC (HDI) were also performed during the inspection period. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and the conditions of your license. The inspection consisted of on-site observations by the inspectors, interviews with site personnel, and a review of procedures and records. The results of this inspection were discussed with members of the Oyster Creek staff on October 21, 2019 and are described in the enclosed report. No violations of safety significance were identified.

In accordance with 10 Code of Federal Regulations (CFR) 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the NRC document system (ADAMS), accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.

Current NRC regulations and guidance are included on the 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 Briana DeBoer at 610-337-5370 if you have any questions regarding this matter.

Sincerely,

/RA/

Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Nuclear Materials Safety Docket No: 50-219 License No: DPR-16 Enclosure:

Inspection Report 05000219/2019003 w/Attachment cc w/encl: Distribution via ListServ

EXECUTIVE SUMMARY

Holtec Decommissioning International, LLC

Oyster Creek Nuclear Generating Station NRC Inspection Report No. 05000219/2019003 An announced quarterly inspection was completed at Oyster Creek Nuclear Generating Station (Oyster Creek) on September 30, 2019. On-site inspections and in-office reviews of information supplied by Holtec Decommissioning International, LLC (HDI) were performed during the inspection period from July 1 to September 30. The inspection included a review of organization and management at the site; self-assessments, audits and corrective actions; decommissioning performance and status reviews; radioactive waste treatment, and effluent and environmental monitoring; and solid radioactive waste management and transportation of radioactive materials.

The inspection consisted of observations by the inspectors, interviews with Oyster Creek personnel, a review of procedures and records, and plant walk-downs. The U.S. Nuclear Regulatory Commissions (NRC's) program for overseeing the safe operation of a shut-down nuclear power reactor is described in Inspection Manual Chapter (IMC) 2561, Decommissioning Power Reactor Inspection Program."

Based on the results of this inspection, no violations of safety significance were identified.

ii

REPORT DETAILS

1.0 Background On September 25, 2018, Oyster Creek certified the permanent removal of fuel from the reactor vessel [Agencywide Documents and Access Management System (ADAMS)

Accession No. ML18268A258]. This met the requirements of 10 Code of Federal Regulations (CFR) 50.82(a)(1)(i) and 50.82(a)(1)(ii). On October 1, 2018, the NRC notified Oyster Creek that the Operating Reactor Assessment Program had ceased and that implementation of the Decommissioning Power Reactor Inspection Program would begin on October 1, 2018 (ADAMS Accession No. ML18274A221). On July 1, 2019, an amended license was issued transferring the license from Exelon Generation Co., LLC to Holtec Decommissioning International, LLC (ADAMS Accession No. ML19164A157).

Oyster Creek is currently in the Actively Decommissioning, Fuel in the Spent Fuel Pool phase of decommissioning as described in IMC 2561.

2.0 Active Decommissioning Performance and Status Review 2.1 Inspection Procedures (IPs) 36801, 40801, 71801

a. Inspection Scope

In-office reviews of information supplied by HDI were performed during the inspection period. The inspectors performed on-site inspections on August 22 and August 29. The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records, and plant walk-downs.

The inspectors conducted document reviews and interviewed plant personnel to determine if regulatory requirements were properly implemented with respect to the site organization, staffing and qualifications, safety, fire protection, and employee concern programs. The inspectors reviewed procedures and processes to evaluate HDIs ability to resolve employee safety concerns, disseminate safety information and effectively resolve identified problems.

The inspectors reviewed documents and interviewed site personnel to determine if issues were identified and corrected in accordance with the sites corrective action program (CAP). The inspectors reviewed a representative selection of CAP documents to determine if a sufficiently low threshold for problem identification existed, follow-up evaluations were of sufficient quality, and HDI assigned timely and appropriate prioritization for issue resolution commensurate with the significance of the issue.

The inspectors reviewed the status of activities related to the site decommissioning to determine if activities are in accordance with licensed requirements. The inspectors reviewed the decommissioning schedule to verify the schedule was consistent with the post shutdown decommissioning activities report (PSDAR).

b. Observations The inspectors verified that management oversight was adequate for the DECON phase of decommissioning. The inspectors verified that there was a formal turnover of the employee concerns program and the quality assurance program to the new licensee and that the programs were being appropriately implemented.

The inspectors determined that issues had been identified and entered into the CAP in a timely manner and the issues were effectively screened, prioritized and evaluated commensurate with their safety significance. The inspectors verified that audits and self assessments were being performed by qualified individuals independent of the organization being audited and that management reviewed the audits and associated corrective actions.

The inspectors noted the next main decommissioning activity is the reactor vessel internal segmentation which is currently in the planning stages. The inspectors verified the schedule was consistent with the September 28, 2018, notification by HDI revising the PSDAR for Oyster Creek.

c. Conclusions

Based on the results of this inspection, no violations of safety significance were identified.

2.2 Radioactive Waste Treatment, and Effluent and Environmental Monitoring (IP 84750)

a. Inspection Scope

The inspectors performed on-site inspection on August 19-22, 2019. The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records, and site walk-downs.

The inspectors reviewed activities and documentation associated with radioactive effluent control and site radiological environmental monitoring program (REMP) to evaluate the effectiveness of site radiological programs. The inspectors reviewed radioactive gaseous and liquid effluent release permits and the Annual Radiological Environmental Operating Report. The inspectors toured the meteorological tower and selected environmental monitoring and sample stations to determine if they were adequately maintained. The inspectors toured solid radiological waste (radwaste) storage facilities to determine if radioactive waste was adequately stored and that containers were labeled as appropriate.

b. Observations The inspectors verified that effluent releases to the environment were being properly controlled, monitored, and quantified as required by NRC regulations. The inspectors verified that the Annual Radiological Environmental Operating Report demonstrated that calculated doses were below regulatory dose criteria of 10 CFR 50, Appendix I. The inspectors determined that the meteorological tower and selected environmental monitoring stations were adequately maintained.

The inspectors noted that HDI had recently identified water intrusion and piping degradation in the reactor building piping vaults. Issue Reports (OYS-00114 and OYS-00163) were generated to document and track the inspections and repair of the piping.

Future NRC inspections will continue to follow the licensees actions.

c. Conclusions

Based on the results of this inspection, no violations of safety significance were identified.

2.3 Solid Radioactive Waste Management and Transportation of Radioactive Materials (IP 86750)

a. Inspection Scope

The inspectors performed an on-site inspection on August 12-14, 2019. The inspection consisted of observations by the inspectors, interviews with site personnel, a review of reports and records, and site walk-downs.

The inspectors reviewed activities and documentation associated with the possession, processing, packaging, storage, and shipment of licensed radioactive material. The inspectors reviewed documentation, logs, and records that were prepared by HDI (the Licensee) and by the former Licensee (Exelon) due to the very recent license transfer between the two.

The inspectors reviewed licensee audits, self-assessments, training & qualification records, procedures, 10 CFR 50.59 screening records, a selection of radioactive waste shipping packages, and corrective action records. The inspectors reviewed any major modifications or changes to the organization, personnel, facilities, or processes for waste management and transportation.

The inspectors toured the Old Radwaste (ORW), New Radwaste (NRW), and Low-Level Radwaste (LLRW) buildings, the NRW Control Room, and the LLRW operating station.

The inspectors examined the outdoor storage location for temporary liquid radioactive waste storage tanks (FRAC tanks).

The inspectors performed a follow-up of concerns regarding the radwaste buildings as documented in NRC inspection report 05000219/2018012 (ADAMS Accession No.

ML19052A085).

b. Observations The inspectors verified that the processing, packaging, storage, and shipment of licensed radioactive material was being performed as required by NRC regulations. No potential public health and safety concerns were identified as a result of transportation activities.

The inspectors noted that, at the time of the inspection, radioactive waste transportation was suspended at Oyster Creek while HDI completed the paperwork with federal, state, waste compact, and disposal facilities that was necessitated by the license transfer from the former licensee (Exelon) to HDI. The inspectors verified that there were two fully-qualified personnel that were authorized shippers for radioactive material, with a third person nearly-qualified.

In an effort to maintain doses As Low As Reasonably Achievable (ALARA) the inspectors reviewed photographs, recent video recordings, and available radiological surveys for areas within the several radwaste facilities that had (or may have had) water, resins, filter sludge, or other waste on the floors.

The inspectors conducted walkdowns and tours of various radwaste facilities and storage areas following the review. The inspectors noted improvement in several features of the LLRW building and the NRW control room that had been raised as concerns during a December 2018 NRC inspection, however not much improvement had been seen in the recovery and clean-up of material on the floors. The inspectors noted that this lack of improvement was likely due to the recent license transfer between HDI and Exelon.

The inspectors determined that the work order backlog for the various radwaste processing systems and facilities was being appropriately prioritized and managed.

At the inspection debriefing, HDI senior managers expressed agreement with the NRCs focus on radioactive material that is not isolated in processing systems or waste containers in radwaste facilities and concurred that this must be factored into the decommissioning planning.

Future NRC inspections will continue to maintain a focus on the following areas:

  • Reactor Building: Filter Sludge Tank Room
  • Reactor Building: Backwash Receiver Tank Room
  • Turbine Building: Hi-Lo Conductivity Demineralizer Tank Room
  • Turbine Building: Condensate Demineralizer Tank Room
  • New Radwaste: SL-T-3A/3B Cubicles
  • New Radwaste: Fill Aisle
  • New Radwaste: SL-T-2A/2B Vaults
  • Old Radwaste: Small Pump Room
  • Old Radwaste: Abandoned Spent Resin Vault
  • Old Radwaste: NV09 Vault
  • Base of Stack: Floor

c. Conclusions

Based on the results of this inspection, no violations of safety significance were identified.

3.0 Exit Meeting On October 21, 2019, the inspectors presented the inspection results to Andrea Sterdis, HDI Vice President Regulatory and Environmental Affairs, and other members of the Oyster Creek staff who acknowledged the inspection results. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Oyster Creek Personnel

P. Cowan, HDI Senior Vice President and Chief Operating Officer
A. Sterdis, HDI Vice President Regulatory and Environmental Affairs
J. Dostal, HDI Oyster Creek Site Vice President
M. Carlson, Site Engineer
J. Chrisman, Radiation Protection Technical Services Manager
R. Csillag, Site DC Engineering Lead
J. Frank, Site DC Regulatory Assurance Lead
D. Helker, Regulatory Assurance Manager
S. Johnson, Site DO Operations Lead
A. Krukowski, Site DO Operations Lead
M. Madonia, Radiation Protection Technician
J. McCarthy, Radiation Protection Decommissioning Specialist
N. Miller, Certified Fuel Handler
E. OBrien, Environmental Specialist
J. Sisak, Manager Work
G. Test, Chemistry Technician
T. Trettle, Site Engineer
H. Tritt, Site DC Engineering Lead
K. Wolf, Manager Radiation Protection and Chemistry
K. Zadroga, Radiation Protection Supervisor

ITEMS OPENED, CLOSED, AND DISCUSSED

None

LIST OF DOCUMENTS REVIEWED