IR 05000255/2024002
| ML24221A159 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/09/2024 |
| From: | Dave Hills NRC/RGN-III |
| To: | Mlynarek M Holtec |
| References | |
| IR 2024002 | |
| Download: ML24221A159 (1) | |
Text
SUBJECT:
PALISADES NUCLEAR PLANT - NRC INSPECTION REPORT NO. 05000255/2024002
Dear Mike Mlynarek:
On June 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Palisades Nuclear Plant. On July 30, 2024, the NRC inspectors discussed the results of this inspection with Jeff Borah, General Manager Plant Operations, and other members of your staff.
The results of this inspection are documented in the enclosed report.
During the inspection, the NRC inspectors reviewed the following aspects of onsite activities:
problem identification and resolution; decommissioning performance; occupational radiation exposure; and radiological environmental monitoring. The inspection consisted of an examination of activities at the site as they relate to safety and compliance with the Commissions rules and regulations.
No violations of more than minor safety significance were identified during this inspection.
August 9, 2024 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, David E. Hills, Chief Decommissioning, Reactor, and ISFSI HP Branch Division of Radiological Safety and Security Docket No: 50-255 License No: DPR-20
Enclosure:
IR Nos. 05000255/2024002
REGION III==
Docket No:
50-255 License No:
DPR-20 Report No:
05000255/2024002(DRSS)
Licensee:
Holtec Decommissioning International, LLC Facility:
Palisades Nuclear Plant Location:
Covert, MI Inspection Dates:
April 01, 2024, to June 30, 2024 Inspectors:
Valerie Myers, Senior Health Physicist Approved by:
David E. Hills, Chief Decommissioning, Reactor, and ISFSI HP Branch Division of Radiological Safety and Security
EXECUTIVE SUMMARY Palisades Nuclear Plant NRC Inspection Report Nos. 05000255/2024002 This U.S. Nuclear Regulatory Commission (NRC) inspection was a routine, announced inspection of decommissioning activities being conducted at the facility. A brief summary of the areas reviewed are described below. Based on the results of the inspection no violations of more than minor safety significance were identified.
Problem Identification and Resolution
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.
Decommissioning Performance and Status Review
The inspectors determined that decommissioning activities were in accordance with the regulations and license requirements.
Occupational Radiation Exposure
Adequate protection of worker health and safety from exposure to radiation and radioactive material was provided. Activities were executed in general alignment with planning documents and as provided in Radiation Work Permits (RWPs) and As-Low-As-Reasonably-Achievable (ALARA) reviews. Radiation surveys were performed adequately to identify the hazards present.
Radioactive Waste Treatment, and Effluent and Environmental Monitoring
The radiological environmental monitoring program (REMP) was implemented in accordance with applicable procedures.
Report Details Summary of Facility Status The Palisades Nuclear Plant is a permanently shut-down and defueled power reactor. During this inspection period, the licensee did not conduct any major decommissioning activities as defined in 50.2. However, the licensee was performing activities related to restart during this period.
2.0 Problem Identification and Resolution at Permanently Shutdown Reactors (IP 40801)
2.1 Inspection Scope The purpose of this portion of the inspection was to evaluate 1) the effectiveness of licensee controls to identify, resolve, and correct issues, 2) the audit and assessment programs, and 3) management reviews of the safety conscious work environment.
2.2 Observations and Findings The inspectors reviewed the Decommissioning Quality Assurance Program (DQAP)
manual and Corrective Action Program (CAP) implementing procedures. The inspectors also reviewed management review committee meeting packages, including review of recently initiated incident reports (IRs), open IRs, open work orders, and work group evaluations being reviewed. No DQAP audits were required to be performed since the last time this inspection was performed so the inspectors verified schedules were in place for required audits. There were no licensee event reports, root cause evaluations, or apparent cause evaluations for review. The inspectors did review a selection of CAP documents to verify that corrective actions were completed as documented and that issues are being identified and addressed in accordance with the CAP.
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.
5.0 Decommissioning Performance and Status Review at Permanently Shutdown Reactors (IP 71801)
5.1 Inspection Scope The purpose of this portion of the inspection was to evaluate the status of decommissioning and to verify the decommissioning activities are in accordance with regulatory and license requirements.
5.2 Observations and Findings On April 9, 2024, HDI submitted a notification of change in accordance with 10 CFR 50.82(a)(7). This change modified the spent fuel management schedule as submitted to the NRC in the Post Shutdown Decommissioning Activities Report (PSDAR). The PSDAR indicated that all fuel would be removed from the Spent Fuel Pool (SFP) and stored on the Independent Spent Fuel Storage Installation (ISFSI) by July of 2025. The notification of change stated that approximately 185 fuel assemblies would remain in the SFP to support restart. HDI stated that the deferral of the full offload of the SFP was the only significant schedule change HDI was implementing at this time.
This notification also stated that HDI expects to exit decommissioning entirely upon reinstatement of the power operations licensing basis and will formally rescind the PSDAR via a subsequent docketed notice. This change is being made to support the Palisades restart project but does not impact the current status of Palisades as a decommissioning facility.
During this quarter the inspectors performed various walkdowns of the facility to include the control room, containment, spent fuel pool, spent fuel cooling system, component cooling system, and engineered safeguards. These walkdowns included observations for radiological postings and controls, general housekeeping, material conditions, and preparation activities for chemical decontamination. In addition, the inspectors conducted bi-weekly meetings with the licensee and attended various plan of the day meetings while on-site to maintain awareness of site activities.
No findings were identified.
5.3 Conclusions The inspectors determined that decommissioning activities were in accordance with the regulations and license requirements.
6.0 Occupational Radiation Exposure at Permanently Shutdown Reactors (IP 83750)
6.1 Inspection Scope The purpose of this portion of the inspection was to evaluate the effectiveness of the licensees occupational radiation safety program to adequately protect worker health and safety from exposure to radiation or radioactive material.
6.2 Observations and Findings Radiologically risk significant work related to restart activities were inspected this quarter utilizing IMC 2562 to assess the licensees occupational radiation safety program and are included in inspection report 05000255/2024011. As review of the occupational radiation safety program under IMC 2562 addresses the same areas as IMC 2561, credit toward IMC 2561 inspection completion is being taken. Below is a brief summary of the areas reviewed.
The inspectors observed and reviewed activities related to the reactor head removal and o-ring replacement in preparation for chemical decontamination. For these evolutions, the inspectors reviewed Radiation Work Permits (RWPs) and As-Low-As-Reasonably-Achievable (ALARA) plans. Observations included 1) airborne control and mitigation practices, including use of temporary ventilation systems and respiratory protection devices, 2) survey practices, including radiation, contamination, airborne radioactivity monitoring, alpha monitoring, and monitoring of individuals and equipment leaving the radiologically controlled area, 3) dosimetry practices, including use of extremity dosimetry and lapel air samplers, and 4) postings and controls for high radiation areas, contamination areas, and alpha areas.
No findings were identified.
6.3 Conclusions Adequate protection of worker health and safety from exposure to radiation and radioactive material was provided. 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.
7.0 Radioactive Waste Treatment, and Effluent and Environmental Monitoring (IP 84750)
7.1 Inspection Scope The purpose of this portion of the inspection was to evaluate the effectiveness of the licensees liquid and gaseous effluent sampling program to quantify radioactive effluent releases and to verify that the radiological environmental monitoring program and groundwater protection initiative were effectively implemented.
7.2 Observations and Findings The inspectors reviewed the annual report submitted to the NRC, the offsite dose calculation manual (ODCM), and implementing procedures associated with the Radiological Environmental Monitoring Program (REMP). The inspectors reviewed a selection of vendor analytical reports for REMP samples to verify results reported to the NRC and to ensure requirements of the ODCM and implementing procedures were met. The inspectors performed walkdowns of REMP air sampling stations and observed licensee staff perform sample collection.
No findings were identified.
7.3 Conclusions The REMP was implemented in accordance with applicable procedures.
10.0 Exit Meeting The inspectors presented the results of the inspection to Jeff Borah and other members of the Palisades Nuclear Plant staff at an exit meeting on July 30, 2024. 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 Site Vice President J. Miksa - Regulatory Assurance Manager G. Wright - Radiation Protection Manager W. Turco - Chemistry Supervisor INSPECTION PROCEDURES (IPs) USED IP 40801 Problem Identification and Resolution 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 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.
- RA-102; Corrective Action Program; Revisions 0
- EN-EC-100; Employee Concerns Program; Revision 14
- EN-LI-108-01; 10 CFR 21 Evaluations and Reporting; Revision 0
- Monthly IR Trend Reports; November 2023 through April 2024
- PAL-01605; NRC Request Charitable Donations Paid Out of DTF; 11/30/2023
- PAL-01861; US NRC Non-Cited Violation HDI Use of Decommissioning Trust Fund; 02/22/2024
- PAL-01663; Part 21 Notification: Bentley Systems Inc; 01/03/2024
- PAL-02525; Typographical Error in 2023 Annual Radiological Environmental Report; 06/20/2024 PAL-02563; PAL-01933 Incorrectly Classified; 06/26/2024
- PAL-02163; P-50C, Primary Coolant Pump, Low CCW Flow Alarm; 04/27/2024
- Work Group Evaluation for PAL-01549, Self-Assessment Observation for Sealed Source Leak Testing; 11/09/2023
- Work Group Evaluation for PAL-01892; Feedwater Purity Building Stop Work; 03/01/2024
- Work Group Evaluation for PAL-02062; Fir tours not performed; 04/10/2024
- WO PAL-02163; FIA-0970A, Component Cooling Heat Exchanger P-50C Alarm; 05/08/2024
- Monthly Review of Fleet OE; April 2024
- Offsite Dose Calculation Manual; Revisions 34 & 35
- Report of Analysis L103931; 01/30/2024
- Report of Analysis L102712; 10/30/2023
- Report of Analysis L103318; 11/30/2023
- PAL-02513; REMP Samples did not meet lower levels of detection; 06/19/2024 LIST OF ACRONYMS USED ADAMS Agencywide Document Access and Management System ALARA As Low as Is Reasonably Achievable CAP Corrective Action Program CFR Code of Federal Regulations DRSS Division of Radiological Safety and Security IP Inspection Procedure IR Incident Report NRC U.S. Nuclear Regulatory Commission ODCM Offsite Dose Calculation Manual PSDAR Post Shutdown Activities Report RWP Radiation Work Permit