IR 05000271/2022002

Northstar Nuclear Decommissioning Company, LLC, Vermont Yankee Nuclear Power Station - NRC Inspection Report No. 05000271/2022002

ML23053A086
Person / Time
Site:	Vermont Yankee
Issue date:	02/22/2023
From:	Anthony Dimitriadis Decommissioning, ISFSI, and Reactor Health Physics Branch
To:	Reid B Vermont Yankee Decommissioning Alliance
References
IR 2022002
Download: ML23053A086 (1)

Text

February 22, 2023

SUBJECT:

NORTHSTAR NUCLEAR DECOMMISSIONING COMPANY, LLC, VERMONT YANKEE NUCLEAR POWER STATION - NRC INSPECTION REPORT NO.

05000271/2022002

Dear Billy Reid:

On December 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection under Inspection Manual Chapter 2561, Decommissioning Power Reactor Inspection Program, at the permanently shutdown Vermont Yankee Nuclear Power Station (VY). On-site inspections were performed August 1-4, October 3-6, and November 14-17, 2022.

Additional inspection activities (in office reviews) were conducted remotely during the inspection period. The inspectors examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and the conditions of your license.

The inspection consisted of observations by the inspectors, interviews with site personnel, and a review of procedures and records. The results of the inspection were discussed with Tom Silko, Licensing Manager, and other members of the VY staff on January 24, 2023, and are described in the enclosed report.

Within the scope of this inspection, no violations of more than minor safety significance were identified.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter, 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, if any, 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 NRCs 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 NRCs 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 Steve Hammann of my staff at 610-337-5399 if you have any questions regarding this matter.

Sincerely, Digitally signed by Anthony M. Anthony M. Dimitriadis Date: 2023.02.22 Dimitriadis 16:56:42 -05'00'

Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Radiological Safety and Security Docket No. 05000271 License No. DPR-28 Enclosure: Inspection Report 05000271/2022002 cc w/encl: Distribution via ListServ

EXECUTIVE SUMMARY

Northstar Nuclear Decommissioning Company, LLC

Vermont Yankee Nuclear Power Station NRC Inspection Report No. 05000271/2022002 An announced decommissioning inspection was completed on December 31, 2022, at the permanently shutdown Vermont Yankee Nuclear Power Station. On-site focused topical inspections were performed August 1-4, October 3-6, and November 14-17, 2022. Additional inspection activities were conducted remotely (in office reviews) during the inspection period.

The inspection included a review of the corrective action program, fire protection, decommissioning performance and status, and effluent and environmental monitoring. The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records, and plant walkdowns. The NRC's program for overseeing the safe decommissioning of a shutdown 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 more than minor safety significance were identified.

REPORT DETAILS

1.0 Background On January 12, 2015, VY certified the permanent removal of fuel from the reactor vessel

[Agencywide Document and Access Management System (ADAMS) Accession No.

ML15013A426]. This met the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.82(a)(1)(i) and 50.82(a)(1)(ii). On January 20, 2015, the NRC notified VY that the Operating Reactor Assessment Program would cease on January 24, 2015, and that implementation of the Decommissioning Power Reactor Inspection Program would begin on January 25, 2015 (ADAMS Accession No.

ML15020A482). On January 11, 2019, an amended license was issued transferring the license from Entergy Nuclear Operations, Inc. to Northstar NDC (ADAMS Accession No.

ML18347B360). VY is in active decommissioning as described in IMC 2561.

2.0 Active Decommissioning Performance and Status Review 2.1 Inspection Procedures 37801, 40801, 64704, 71801, 84750

a. Inspection Scope

The inspectors conducted document reviews and interviews with plant personnel to determine if Northstar procedures and processes were in compliance with the regulations and guidance associated with 10 CFR 50.59. The inspectors also reviewed Northstars applicability determination process that is used to determine if a 10 CFR 50.59 evaluation was required. The inspectors reviewed the qualification and training for 10 CFR 50.59 and process applicability determination evaluators and screeners.

The inspectors reviewed documents and interviewed VY personnel to determine if Northstar management performed self-assessments and 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 if Northstar assigned timely and appropriate prioritization for issue resolution commensurate with the significance of the issue. The inspectors reviewed site self-assessments for the past year to determine if they were thorough and if corrective actions were initiated, as appropriate.

The inspectors interviewed personnel, reviewed documentation, and performed plant walkdowns to determine if the licensee maintained a fire protection program (FPP) to address the potential for fires that could cause the release or spread of radioactive material. The inspectors reviewed the fire protection plan and a sample of the implementation procedures to assess compliance with the current plan, to assess if they reflected the current decommissioning status of the facility, and if the procedures were implemented, as appropriate. The inspectors walked down several fire areas to determine if they were as described in the sites pre-fire plans. The inspectors reviewed hot work permits and surveillances of fire protection equipment to determine if they were performed on a regular basis.

The inspectors performed a walkdown of the plant to evaluate housekeeping and the material condition of the site. The inspectors reviewed radiological surveys and observed work-in-progress for demolition of the administration building, control/services building, reactor building airlock, and containment access building to assess adherence to regulations and site work plans and procedures. The inspectors performed walk-downs of the reactor building to review progress for the removal of piping and components. The inspectors observed processing of the greater than class C (GTCC) waste container and reviewed procedures, work plans, and assessments for loading the GTCC waste container and movement and storage of the GTCC waste container.

The inspectors reviewed activities and documentation associated with effluent and environmental monitoring programs to determine if the licensee effectively controlled, monitored, and quantified releases of radioactive materials to the environment. The inspectors performed a walkdown of the gaseous monitoring system and discharge point to determine the alignment and material condition of equipment. The inspectors walked down selected dosimetry stations and monitoring wells to determine accessibility, material condition, and whether they were located as described in the Off-Site Dose Calculation Manual (ODCM). The inspectors reviewed procedures, the annual radiological environmental monitoring program (REMP) report, the annual radioactive effluent report, and the ODCM.

NRC contractors from Oak Ridge Institute for Science and Education (ORISE) were on-site and performed a confirmatory survey of cooling tower basin 2 and land area between the basins. The inspectors reviewed Northstar radiological surveys and performed a walkover survey of the interim off gas (IOG) trench prior to Northstar backfilling the trench.

b. Observations and Findings

The inspectors determined that Northstar had trained and qualified individuals to perform the 10 CFR 50.59 screenings and evaluations. The inspectors determined that no changes or modifications under 10 CFR 50.59 were made in the past year.

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 self-assessments had been performed by qualified individuals independent of the organization being audited and that management reviewed the assessments and associated corrective actions.

The inspectors determined that Northstar maintained the FPP within NRC requirements and the fire protection plan minimized the potential for radiological releases in the event of a fire at the plant. The inspectors verified fire protection equipment and fire water supply systems had been maintained and appropriately tested and were in a state of operational readiness. The inspectors verified staffing and training of the on-site incipient fire brigade was adequate and agreements were appropriately established with the local fire department to be the primary responder for onsite fires.

The inspectors noted during the plant walk-downs that housekeeping and plant material condition standards had been maintained. The inspectors determined that Northstar demolition activities were performed safely and in accordance with work plans and plant procedures and that radiation protection technicians effectively maintained radiological controls for the work-in-progress. The inspectors determined the loading, movement, and storage of GTCC waste was in accordance with NRC regulations. The inspectors verified the activities and schedule were consistent with license requirements and the site Post Shutdown Decommissioning Activities Report.

The inspectors determined that effluent releases to the environment had been properly controlled, monitored, and quantified in accordance with NRC regulatory requirements.

The inspectors verified that the annual radiological effluent and the annual REMP reports demonstrated that calculated doses were below regulatory dose criteria of 10 CFR Part 50, Appendix I. Additionally, the inspectors verified effluent sampling equipment and area radiation monitors were checked, calibrated, and maintained as specified in the ODCM. The inspectors verified that sampling stations were accessible and as described in the ODCM.

The ORISE confirmatory survey report of cooling tower basin 2 and the adjacent land had not been issued prior to the issue of this report and will be referenced in a future inspection report. The walkover survey of the IOG trench was performed using a NaI(Tl)scintillator detector and no readings above background were found.

c. Conclusions

No violations of more than minor safety significance were identified.

3.0

Exit Meeting Summary

On January 24, 2023, the inspectors presented the inspection results to Tom Silko, Licensing Manager, and other members of Northstar NDC staff who acknowledged the inspection results. No proprietary information was retained by the inspectors or documented in this report.

PARTIAL LIST OF PERSONS CONTACTED Licensee B. Reid, Vice President D. Pearson, Vice President C. Daniels, ISFSI Sr. Manager N. Langub, Decommissioning Project Manager D. Giard, ISFSI Administrator R. Mauthe, ISFSI Technical Specialist A. Miller, RP Supervisor S. Naeck, ISFSI Operations Manager M. Pletcher, Radiation Protection Manager R. Routhier, Facility Area Manager T. Silko, Licensing Manager D. Toegel, Power Block Area Manager J. Ward, Maintenance Technical Specialist State of Vermont T. Leshinskie, Nuclear Engineer ITEMS OPEN, CLOSED, AND DISCUSSED None LIST OF

DOCUMENTS REVIEWED

Condition Reports

CR- 2022 - 00155, 00157, 00159, 00181, 00185, 00211, 00221

Procedures and Programs

NSVY-CY-4601, Revision 1, Environmental Radiation Surveillance Program

NSVY-EV-4605, Revision 1, Environmental Radiation Sampling and Analysis

NSVY-CY-7605, Revision 1, Groundwater Monitoring Plan

NSVY-CY-110 , Revision 0, Chemistry Gamma Spectroscopy System Operation,

Count Room Tasks

NSVY-CWP-ORANO-0079, Revision 0, Install and Operate Media Filtration System

NSVY-EV-2630, Revision 0, Analytical Instrumentation

NSVY-FP-127, Revision 1, Control of Hot Work and Ignition Sources

NSVY-FP-4103, Revision7, Fire Protection Systems and Equipment Surveillance

NSVY-FP-10184, Revision 2, Plant Side Fire Protection Program

NSVY-RP-141, Revision 0, Job Coverage

NSVY-RP-141-02, Revision 0, Discrete Radioactive Particle Control

NSVY- RP-2525, Revision 0, Calibration and Operation of the Ludlum GM and Alpha Counters

NSVY-RP-302, Revision 0, Operation of Radiation Protection Instrumentation

NSVY-RW-2511, Revision 0, Radwaste Cask/Liner Handling

Vermont Yankee Nuclear Power Station, Fire Brigade Pre-Fire Plans, Revision 15

Procedures and Programs (Contd)

Vermont Yankee Nuclear Power Station, Fire Hazards Analysis, Revision 22

VY-AD-7, Revision 3, Corrective Action Program

VY-AD-9, Revision 3, Process Applicability Determination Process and Regulatory Reviews

Miscellaneous

Hot Work Permits; RB 345 7/5/22, Big Top 4/7/22, Torus Room 11/2/22, RB 280 11/9/22

Independent Management Assessment, Vermont Yankee Nuclear Power Station, Sept 26, 2022

Monorail System - Supporting Calculations, Vermont Yankee Demolition & Cleanup Project

Monthly Fire Extinguisher Surveillance, 10/25/22

QS-2022-VY-001, Independent Assessment of the Emergency Preparedness Program

QS-2022-VY-002, Preparations for Greater than Class C Waste Project

QS-2022-VY-006, Packaging & Processing and Transport of the GTCC Waste

Survey logbook #22-0493, 0494, 0495, 0600, 0601, 0602, 0620, Site A CAB, RB 252H

Transportation Packages NSVY-2022-110 and NSVY 2022-111

VY Characterization Survey Planning Worksheet, NORA2,01-E01 and 02-

Waste Shipment Log

Work Packages and Plans

CALC-DDOPS.VTY-00014, VY RVI GTCC Package Characterization Record

Design Change Record (DCR) Documentation Package DCR-21-01-0

GTCC-TRWP-128, Process GTCC and move to ISFSI Pad

NFWC Loading Preparations and Sealing Operations

NFWC Processing

LIST OF ACRONYMS USED

ADAMS Agencywide Document and Access Management System

CAP Corrective Action Program

CFR Code of Federal Regulations

DOT Department of Transportation

FPP Fire Protection Program

GTCC Greater Than Class C

IMC Inspection Manual Chapter

IOG Interim Off Gas

ISFSI Independent Spent Fuel Storage Installation

NaI Sodium Iodide

Northstar NDC Northstar Nuclear Decommissioning Company, LLC

NRC U.S. Nuclear Regulatory Commission

ODCM Offsite Dose Calculation Manual

ORISE Oak Ridge Institute for Science and Education

PHE Public Health Emergency

REMP Radiological Environmental Monitoring Program

RP Radiation Protection

Tl Thalium

TS Technical Specification

VY Vermont Yankee Nuclear Power Station

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