IR 05000219/2021003
| ML21320A025 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 11/16/2021 |
| From: | Anthony Dimitriadis Decommissioning Branch I |
| To: | Trice K Holtec Decommissioning International |
| References | |
| IR 2021003 | |
| Download: ML21320A025 (11) | |
Text
November 16, 2021
SUBJECT:
HOLTEC DECOMMISSIONING INTERNATIONAL, LLC, OYSTER CREEK NUCLEAR GENERATING STATION - NRC INSPECTION REPORT NO.
05000 219/202 1003
Dear Mr. Tric e:
On September 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection under Inspection Manual Chapter 256 1, Decommissioning Power Re actor Inspection Program, at the permanently shut down Oyster Creek Nuclear Generating Station (Oyster Creek). On-site inspections were performed on July 12-14, 2021, August 11-12, 2021, and September 22-23, 2021. Additional inspection activities (in office reviews) were conducted remotely as a consequence of the COVID-19 public health emergency (PHE)
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 plant walk-downs by the inspectors, interviews with site personnel, and a review of procedures and r ecords. The results of this inspection were discussed with Mr. Jeffrey Dostal, Site Vic e Pres ident, and other members of the Oyster Creek staff on October 18, 2021 and a re described in the enclosed report.
Within the scope of this inspection, no violations were identified.
In accordance with 10 Code of Federal Reg ulations (CFR) 2.39 0 of the NRC's "Rules of Practice," a copy of this letter and it s 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.
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 current Enforcement Policy is included on the NR C's website at www.nrc.gov; select About NRC, Organizations & Functions; Office of Enforcement; Enforcement documents; then Enforcement Policy (Un der 'Related Information'). You may also obtain these documents by contacting the Government Printing
K. Tric e 2
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).
No reply to this letter is required. Please contact Elizabeth Andrews at 610- 337-511 7 if you have any questions regarding this matter.
Sincerely, Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Radiological Safety and Security
Docket No: 050 00219 License No: DPR-16
Encl osure: Inspection Report 05000219/ 202100 3 w/Attachment
cc w/encl: Distribution via ListServ
K. Trice 3
HOLTEC DECOMMISSIONING INTERNATIONAL, LLC, OYSTER CREEK NUCLEAR GENERATING STATION - NRC INSPECTION REPORT NO. 0500021 9/202100 3, DATED NOVEMBER 16, 2021.
DOCU MENT NAME: https://usnrc.sharepoint.com/:w:/r/teams/Region -I-Decommissioning-Branch/_layouts/15/Doc.aspx?sourcedoc=%7Bca5d61f0- 9292-4da8-abb3-ae909230e34a%7D&action=edit&wdPid=4c3f8063
SUNSI Review Complete: EAndrews ML21320A025 Af te r d ec l ar i ng this document An Official Agency Record it will be released to the Public.
T o receive a copy of this document, indicate in the box: C = Copy w/o attach/encl E = Copy w/ attach/encl N = No copy OFFICE DRSS/R I N DRSS/R I N NAME E.Andrews/ea A.Dimitriadis/a d DATE 11/1/21 11/16/21
OFFICIAL RECORD COPY U.S. NUCLEAR REGULATORY COMMISSION
REGION I
INSPECTION REPORT
Docket No: 050- 00219
License No: DPR-16
Report N o: 05000 219/202 1003
Licensee: Holtec Decommissioning International, LLC
Facility: Oyster Creek Nuclear Generating Station
Location: Forked River, New Jersey
Dates: July 1, 2021 - September 30, 2021
Inspectors: E. Andrews, Health Physicist B. DeBoer, Health Physicist
Approved by: Anthony Dimitriadis, Chief Decommissioning, ISFSI and Reactor Health Physics Branch Division of Radiological Safety and Security
Enclosure EXECUTIVE SUMMARY
Holtec Decommissioning International, LLC Oyster Creek Nuclear Generating Station NRC Inspection Report No. 050 0021 9/ 20210 03
An announced decommissioning inspection was completed at Oyster Cree k Nuclear Generating Station (Oyster Creek) on September 30, 2021. Additional inspection activities were conducted remotely during the inspection period as a consequence of the COVID-19 public health emergency (PHE). The inspection included a review of safety reviews, design changes and modifications at permanently shutdown reactors; problem identification and resolution at permane ntly shutdown reactors; the fire protection program at permane ntly shutdown reactors; decommissioning performance and status reviews; and occupational radiation exposure at permane ntly shutdown reactors. The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records, and pl ant walk-downs. The U.S. Nuclear Regulatory Commissions (NRC's) program for overseeing th e safe decommissioning of a s hut-down nuclear po wer re actor is described in Inspection Manual Chapter (IMC ) 2561, Decommissioning Power Re actor Inspection Program."
Based on the results of this inspection, no violations were identified.
ii REPORT DET AILS
1.0 Background
On September 25, 2018, Oyster Creek certified the permanent removal of fuel from the reactor vessel [Agencywide Document Access and Management S y st em (ADAMS)
Accession No. ML18268A258]. This met the requirements of 10 Code of Federal Regulations (CF R) 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 woul d 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 De commissioning Performance and Status Review
2.1 Inspection Procedures 37801, 40801, 6470 4, 71801, 8375 0
a. Inspection Scope
In-office reviews of information supplied by Oyster Creek were performe d during the inspection period. The inspectors performed on-site inspections on July 12-15, 2021, August 11-12, 2021, and September 22-23, 2021. The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedur es and records, and plant walk-do wns.
The inspectors conducted document reviews and interviews with plant personnel to determine if Holtec implemented procedures and pr ocesses in accordance with the regulations and guid ance associated with 10 CFR 50.59, Changes, tests and experiments. The inspectors reviewed a selection of modifications, design changes, and 10 CFR 50.5 9 screenings to determine if the modifications and design changes would nee d prior N RC ap proval prio r to implementation of the activity. The inspectors reviewed a sample of modification, design changes and 10 CFR 50.59 screenings associated with abnormal operating pr ocedure r evisions, equipment abandonment packages, greater-than-class C waste on the independent spent fuel storage installation (ISFSI) pad, site fire panels in preparation to the sites transition to the ISFSI Island security posture, and an update to the defueled safety analysis report to support the ISFSI Only Technical Specifications. The inspectors interviewed personn el and reviewed the engin eerin g change and modification packages, condition reports, and plant drawin gs to determine if the modification met the requirements of the technical specifications.
The inspectors reviewed documents and interviewed site personnel to determine if HDI performed a udits and self-assessment and ensured issues were identified and corrected in accordance with the sites corrective action program (CAP). The inspectors interviewed a rep resentative selection of CAP documents and attended CAP-related meetings to determine if a sufficiently low threshold for problem identification existed, follow-up evaluations wer e of sufficient quality and HDI assigned timely and approp riate prioritization for issue resolution commensurate with the significance of the issue.
The inspectors reviewed the status of the fire protection program to determine if the progr am was maintained in a state of operational rea diness and whether changes made to the program continued to meet commitments, the NRC requirem ents, and had not negatively impacted the overall state of the program. The inspectors reviewed fire brigade traini ng and trainin g with off-site responders. Additionally, the inspec tors performed a w alkdown of the firefighting equipment storage areas, active plant detection and suppression systems, and fire barriers to ensure material condition wa s maintained.
The inspectors reviewed the status of activities related to the site decommissioning to determine if activities were in accordance with licensed requirements. The inspectors observed a sample of ongoing decommissioning activities, including the demolition of the augmented offgas building. The inspectors reviewed the decommissioning schedule to determine if the schedule was consistent with the post shutdown decommissioning activities report (PSDAR).
The inspectors also reviewed the occupational radiation exposure pr ogr a m to determine if it met regulatory requirements and observed a sample of radiation prote ction job coverage of work activities, toured the radiologically controlled areas, and interviewed radiation wo rkers. The inspectors reviewed dose records for 2020 and 20 21, radiation surveys, as low as reasonably achievable (ALARA) plans, radiation work permits, and radiation protection proced ures. The inspectors also reviewed training an d qualifications of radiation protection staff.
b. Observations and Findings
The inspectors verified that the selection of modifications, design changes, and 10 CFR 50.59 screenings followed established procedur es, and the individuals performing the reviews were trained a nd qualified. The inspectors assessed the details of the evaluations, evaluated that the licensees judgments were appro priate, an d determined that key considerations were effectively evaluated to maintain plant s afety. The 10 CFR 50.59 screening for the defueled safety analysis report to support the ISFSI Only Technical Specifications appropri ately determined that a license amendment was requir ed. The NRC subsequently reviewed an d appr oved Oyster Creek License Amendment 299 (ML21119A064 ) to transition the site to ISFSI Only Technical Specifications, which took effect on July 24, 2021.
The inspectors determined that issues had been identified and entered int o 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 performed by qualified individuals independ ent of the organization being audited, and man agement review ed the audits and associated corre ctive actions.
The inspectors verified the fire protection program was maintained within NRC requir ements and the fire protection plan. The inspectors reviewed the updated fire protection plan and a sample of the fire protection program implementation procedur es and verified compliance with the current fire protection program, ensured that they reflected the current decommissioning status of the facility, and verified they were implemented, as appropriate. The inspectors also reviewed fire response training an d observed a continuous fire watch put in place due to a fire water system leak.
The inspectors noted the next main decommissioning activities include building demolition and reactor segmentation, which were in pro gress at the time of the exit meeting of this inspection period. The inspectors determined the activities were performed safely and in accordance with work plans. The inspectors also verified the activities and schedule were consistent with the September 18, 2018, notification by HDI revising the PSDAR for Oyster Creek.
The inspectors determined that the radiation protection staff effectively controlled work activities, that survey records were clear and complete, and radiation prote ction technicians used appropriate instruments for surveys. The inspectors also verified technician training and qualifications were complete and up to date, and that ALARA plans were perfo rmed as neede d and we re effective in limiting worker exposure, and occupational dose was acceptable for the scope of the radiological activities performed.
c. Conclusions
Based on the results of this inspection, no violations were identified.
3.0 Exit M ee ting
On October 18, 2021, the inspectors presented the inspection results to Mr. Jeffrey Dostal, Site Vice President, and other members of the Oyster Creek staff who acknowledged the inspection results. No proprietary information was retai ned by the inspectors or documented in this report.
ATTACHMENT: SUPPLEMENTAL INFORMATION
SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT
Oyster Creek Personnel
K. Tric e, HDI President A. Sterdis, HDI Vice President Regulatory and Environmental Affairs J. Dostal, HDI Oyster Creek Site Vice President L. Berlinski, Oversight Assessor M. Carlson, Engineer R. Fitts, Corrective Action Process Manager M. Hassler, Decommissioning Manager S. J ohns on, Site Licensing Manager K. Leonard, Waste Removal Manager T. Prosser, Fire Marshal J. Sisak, Decommissioning Facility Manager H. Tritt, Site Engineering Manag er K. Wolf, Radiation Protection, Chemistry, and Environmental Manager
ITEMS OPENED, CLOSED, AND DISCUSSED
None
LIST OF DOCUMENTS REVIEWED
2.1 Inspection Procedures 37801, 40801, 6470 4, 71801, 8375 0
Procedures 101.2, Oyster Creek Site Fire Protection Program, Revision 77 645.2.027, Fire Pump Diesel Quarterly Battery Surveillance, Revision 14 645.6.013, Fire Suppression System Halon Functional Test, Revision 47 ABN-29, Plant Fires, Revision 35 CC-AA-50 1-10 27, Hot Work Precautions and Safety Practices, Revision 1 OP-AA-201- 00 9, Control of Transient Combustible Material, Revision 23 OP-DC-201- 007, Fire Protection System Impairment Control, Revision 1 RP-AA-700- 1 002, Determin ation of Correction Factors for Radiation Protection Neutron Instrumentation, Revision 1
Condition Re ports OYS-00568 OYS-00750 OYS-01318 OYS-01619 OYS-01642 OYS-01675 OYS-01683 OYS-01853 OYS-01940 OYS-01977 OYS-01978 OYS-01979 OYS-01980 OYS-01981 OYS-02000 OYS-02018 OYS-02021 OYS-02050 OYS-02056 OYS-02077 OYS-02088 OYS-02110 OYS-02117 OYS-02132 OYS-02137 OYS-02163 OYS-02169 OYS-02170 OYS-02183 OYS-02191 OYS-02195 OYS-02200 OYS-02206 OYS-02207 OYS-02216 OYS-02219 OYS-02221 OYS-02222 OYS-02223 OYS-02243 OYS-02246 OYS-02251
Miscellaneous 50.59 Review for ABN-16, Loss of Fuel Pool Cooling, Revision 0 50.59 Review for DSAR Update to IOTS (ISFSI ONLY Technical Specifications), Revision 1 20- 90 6, ISFSI Campaign Utilizing HI-STORM FW System ALARA Plan, dated Februa ry 23, 2021 21-90 5A, Reactor Segmentation, dated April 1, 2021 ALARA Work-In-Progress Review, dated April 5, 2021 ALARA Work-In-Progress Review, dated May 10, 2021 Annual Station ALARA Committee Meeting Minutes, dated December 8, 2020 AUDIT 2020- I10, Internal Audit Report: Fire Protection DC-AA-42 0- 20 20- 002, New R adw aste Building Abandonment DSP-EN-001-202 1- 00 2, South Flex Storage Area DPS-EN-001-202 1- 00 9, Heating Boiler Houses N-AN-SA-FIREWATCH-PRAC, Fire Extinguisher (Fire Watch) Practical N-OC-SA-FB-Ct-QRT, Quarte rly Fire Brigade Requ al OC-20 21-EC-000 2, Fire Panel Monitoring Modification, Revision 0 OC-20 21-EC-000 3, HI-SAFE FW GTCC Waste Storage West of ISFSI Pad, Revision 0 Oyster Creek Nuclear Generating Station Fire Hazards Analysis Report, Revision 21 Oyster Creek Part 37 & ISFSI Only Plant Access Training Oyster Creek Reactor Vessel/Reactor Vessel Internal Segmentation Project, Revision 1 Radiation Wo rker Training Work Package 000070B, Demo CST, Revision 0
Radiological Surveys CAA-21-21 50, Cond ensate Storage Tank, dated July 19, 2021 CAA-21-21 96, Cond ensate Storage Tank, dated July 22, 2021 CAA-21-23 97, Cond ensate Storage Tank, dated August 9, 2021 PPA-21-2027, NR W Pump Room, dated June 29, 2021 PSB-21-2214, ORW C ontrol Room & Precoat Room, dated July 24, 2021 PTP-21-221 7, ORW Operating Aisle/Storage Area, dated July 24, 2021 PUU-21-210 7, ORW Inside Tank Room, dated July 8, 2021 RCT-21-22 93, Reactor Building 23, dated August 3, 2021 REY-21-22 94, Reactor Building 51, dated August 3, 2021 RFQ-21-228 3, Reactor Building 75, dated August 2, 2021 RGU-21-2 282, Reactor Building 95, dated August 2, 2021 RH3-21-2 222, Reactor Building 119, dated July 26, 2021 UAB-21-24 05, ORW West Tanks, dated August 10, 2021 WAA-21-13 80, Low Level Rad Waste Storage Facility, dated May 12, 2021 WAA-21-19 58, Low Level Rad Waste Storage Facility, dated June 24, 2021
Radiological Work Permits OC-1-21- 0030 1, Condensate Storage Tank, Clean, Paint - Remove Tank, Revision 0 OC-1-21- 0090 5, RB 119 - Reactor Building Segmentation and Packaging, Revision 1 OC-1-21- 0090 6, ISFSI & GTCC Campaign an d Support Activities, Revision 5
Surveillances and Work Orders 1-OYC-OP-OP-00196993 01-2125 1-OYC-OP-OP-0019 8456 01-2109 1-OYC-OP-OP-0019 8456 02-2124 1-OYC-OP-OP-0023 9786 0101 212 9 1-OYC-OP-OP-0025 2149 02-2107 1-OYC-OP-OP-0025 2152 01-2107 1-OYC-OP-OP-0025 2169 01-2044
LIST OF ACRONYMS USED
ADAMS Agencywide Document Access and Management S ys t em ALARA as low as reasonably achievable CAP corrective action program CFR Code of Feder al Regulations HDI Holtec Decommissioning International, LLC IMC inspection manual chapter ISFSI indepen dent spent fuel storage installation NRC U.S. Nuclear Regulatory Commission Oyster Creek Oyster Creek Nuclear Generating Station PHE public health emergency PSDAR post shutdown decommissioning activities report
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