IR 05000271/2023002
| ML24043A157 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 02/20/2024 |
| From: | Anthony Dimitriadis NRC Region 1 |
| To: | Reid B Vermont Yankee |
| References | |
| IR 2023001 | |
| Download: ML24043A157 (1) | |
Text
February 20, 2024
SUBJECT:
NORTHSTAR NUCLEAR DECOMMISSIONING COMPANY, LLC, VERMONT YANKEE NUCLEAR POWER STATION, NRC INSPECTION REPORT NOS.
05000271/2023002 AND 07200059/2023001,
Dear Billy Reid:
On December 31, 2023, 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). 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, a review of procedures and records, and plant walk downs. The results of the inspection were discussed with you and other members of your staff on January 23, 2024, 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 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response, 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 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).
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD, SUITE 102 KING OF PRUSSIA, PA 19406-1415 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, Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Radiological Safety and Security
Docket Nos.
05000271 and 07200059 License No.
Enclosure:
Inspection Reports 05000271/2023002 and 07200059/2023001
cc w/encl:
Distribution via ListServ
Anthony M.
Dimitriadis Digitally signed by Anthony M. Dimitriadis Date: 2024.02.20 13:07:11 -05'00'
EXECUTIVE SUMMARY
Northstar Nuclear Decommissioning Company, LLC
Vermont Yankee Nuclear Power Station NRC Inspection Report Nos. 05000271/2023002 and 07200059/2023001
A routine announced decommissioning inspection was completed on December 31, 2023. On-site inspection activities were performed August 14-17, October 10-12, and December 11-14, 2023. Additional inspection activities (in office reviews) were conducted remotely during the inspection period. The inspection included a review of plant modifications, fire protection, decommissioning performance, and status, radwaste storage and transportation, and the Independent Spent Fuel Storage Installation (ISFSI). 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." The NRCs program for overseeing the safe operation of dry storage of spent fuel at an ISFSI is described in IMC 2690, Inspection Program for Storage of Spent Reactor Fuel and Reactor Related Greater-Than-Class Waste at Independent Spent Fuel Storage Installations and for 10 CFR Part 71 Transportation Packagings.
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 10 Code of Federal Regulations (CFR)50.82(a)(1)(i) and 50.82(a)(1)(ii). On January 20, 2015, the NRC notified VY that it would no longer provide its oversight activities using the Operating Reactor Assessment Program, 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
a. Inspection Scope
(Inspection Procedures 37801, 64704, 71801, 83750, 86750)
The inspectors conducted document reviews and interviews with plant personnel to determine if NorthStar NDC procedures and processes were in compliance with the regulations and guidance associated with 10 CFR 50.59. The inspectors also reviewed Northstar NDCs applicability determination process that is used to determine if a 10 CFR 50.59 evaluation was needed and reviewed a sampling of 10 CFR 50.59 screenings. The inspectors reviewed the qualification and training for 10 CFR 50.59 and process applicability determination evaluators and screeners.
The inspectors interviewed site personnel, reviewed documentation, and performed plant walkdowns to determine if VY maintained a Fire Protection Program (FPP) to address the potential for fires that could cause the release or spread of radioactive materials. The inspectors reviewed the fire protection plan and a sample of the implementation procedures to assess compliance with the current plan, to determine if they reflected the current decommissioning status of the facility, and to determine if they were being implemented, as appropriate. The inspectors performed walked downs of the fire service pump area to evaluate its physical condition and to assess if it was effectively maintained. Additionally, the inspectors performed walked downs of several fire areas to determine if they were as described in the sites pre-fire plans. The inspectors reviewed surveillances of fire protection equipment to evaluate if they were performed on a regular basis in accordance with the requirements.
The inspectors attended a number of licensee meetings, including plan-of-the-day meetings, safety meetings, and pre-job briefings, and reviewed the current status of the overall project to determine compliance with the license, Technical Specifications (TS),and Post Shutdown Decommissioning Activities Report (PSDAR). The inspectors performed walkdowns of the site and evaluated housekeeping and assessed area radiological conditions and radiological access controls, including posting and labeling practices. The inspectors observed ongoing work activities including removal of reactor building piping and components, surveys of turbine building structural steel, and demolition of turbine building concrete to ensure compliance with site work plans and procedures. The inspectors observed radiological controls and Radiation Protection Technician (RPT)job coverage for the work-in-progress activities to determine if radiological controls were adequate for the work being performed.
The inspectors observed activities, interviewed personnel, performed walkdowns and reviewed documentation to assess the licensees programs for handling, storage, and transportation of radioactive material. The inspectors observed workers handling and packaging radioactive waste and performed a walk-down of radioactive waste storage locations to evaluate if the licensee had properly classified and stored radioactive materials. The inspectors observed personnel surveying, labeling, and placarding vehicles used for transporting radioactive waste and reviewed work packages for shipments of radioactive waste. The review included records of shipment packaging, surveying, labeling, marking, placarding, vehicle checks, and emergency instructions to determine compliance with the applicable NRC and Department of Transportation (DOT)regulations. The inspectors reviewed the training program and records to determine if radwaste personnel were qualified to appropriately implement the site solid radwaste program.
b. Observations and Findings
The inspectors determined that 10 CFR 50.59 screenings had been performed and that Northstar NDC had trained and qualified individuals to perform the 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 Northstar NDC maintained the FPP within NRC requirements and the fire protection plan to minimize the potential for radiological releases in the event of a fire at the plant. The inspectors verified fire protection 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 personnel was adequate and agreements were appropriately established with the local fire department to be the primary responder for on-site fires.
The inspectors noted management had maintained a high level of engagement regarding all aspects of the project and worker safety was prioritized during meetings.
The inspectors determined during the site walk-down that housekeeping, and plant material condition standards were being maintained. The inspectors determined that Northstar NDCs activities were performed safely and in accordance with work plans and plant procedures and that RPT s effectively maintained radiological controls for the work-in-progress. The inspectors verified the activities and schedule were consistent with license requirements and the site Post Shutdown Decommissioning Activities Report. The inspectors performed a walkover radiological survey of the AOG Trench Survey Unit NORA1-02-E01, and a portion of the trench overburden, with a sodium iodide detector and no readings above background were detected.
The inspectors verified solid radioactive waste was adequately stored and monitored and worker radwaste training and qualifications were up to date. The inspectors also verified that radioactive waste shipping paperwork was properly completed and Northstar NDC personnel were knowledgeable of their duties and responsibilities. The inspectors determined radioactive waste shipped was properly classified, described, packaged, marked, and labeled, and was in proper condition for transportation.
The inspectors determined the licensees radwaste shipments were in compliance with NRC and DOT regulations.
c. Conclusions
No violations of more than minor safety significance were identified.
3.0 Independent Spent Fuel Storage Installation (ISFSI)
3.1 Operation of an Independent Spent Fuel Storage Installation (Inspection Procedure 60855)
a. The inspectors assessed whether Northstar NDC personnel were operating and maintaining ISFSI programs in conformance with the commitments and requirements contained in the Final Safety Analysis Report, Safety Evaluation Report, Certificate of Compliance (CoC), Technical Specifications (TS), Quality Assurance Program (QAP),
Northstar NDC procedures, and 10 CFR Part 72.
ISFSI facilities, located at sites where loading operations have been completed, are essentially passive operating facilities. The inspectors review was directed towards confirming the ongoing adequacy of the radiation protection, fire protection, emergency preparedness, surveillance, maintenance, environmental monitoring, training, QAP, and corrective action programs.
The inspectors observed cask temperature monitoring activities, interviewed personnel, and reviewed records and procedures. The inspectors also reviewed changes made to Northstar NDCs programs and procedures since the last inspection to determine if changes were consistent with the license or CoC and if they reduced the effectiveness of the program.
b. Observations and Findings
The inspectors verified that special nuclear material stored at the ISFSI was properly accounted for. Dosimetry records and environmental monitoring reports were reviewed. All exposures were below the regulatory dose limits and the dose requirements for members of the public at the nearest accessible location to the ISFSI were within limits prescribed by 10 CFR 72.104.
Northstar NDCs emergency preparedness program properly coordinated with the appropriate offsite support groups, agencies, and local law enforcement agencies.
The emergency call list was properly updated and checked periodically for accuracy.
Daily temperature monitoring of the HI-STORM casks was performed by VY personnel in accordance with surveillance requirements in the TS. Northstar NDCs procedures contain backup plans if the primary surveillance method was unavailable.
The inspectors performed a walk-down of the ISFSI pad and did not note any significant material condition issues that would impact the performance of the pad and loaded casks. The inspectors also verified that transient combustibles were not being stored on the ISFSI pad or in the vicinity of the casks and confirmed vehicle entry onto the ISFSI pad was controlled in accordance with site procedures.
c. Conclusions
No violations of more than minor safety significance were identified.
4.0
Exit Meeting Summary
On January 23, 2024, the inspectors presented the inspection results to Billy Reid, Site Vice President, 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 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
Audits and Reports
Trend Review Summary Report - 1 July to 31 December 2022
Trend Review Summary Report - 1 January to 30 June 2023
VY-A-23-01, Site Audit (ISFSI Operations and Radiological Programs)
Report of Analysis/Certificate of Conformance, L101476, L102061, L102423, L101623
Condition Reports
CR-2023 - 000142, 000143, 000151, 000152, 000161, 000165, 000166
Procedures and Programs
NSVY-RP-201, Rev. 0, Dosimetry Administration
NSVY-RW-102, Rev. 4, Radioactive Shipping Procedure
NSVY-RW-106, Rev. 1, Integrated Transportation Security Plan
NSVY-RW-107, Rev. 0, Waste Packaging and Transportation Plan
NSVY-RW-108, Rev. 0, Radioactive Shipment Accident Response
NSVY-RW-2511, Rev. 1, Radwaste Cask/Liner Handling
NSVY-RW-2511-02, Rev 1, Technical 3002, Cask Handling Procedure for US DOT
Specification 7A Type A Transportation Cask
NSVY-RW-2512, Rev. 0, Radioactive Material/Radioactive Waste Packaging
VY-AD-5, Rev. 4, ISFSI Work Control
VY-AD-9, Rev. 3, Process Applicability Determination Process and Regulatory Reviews
VY-AD-28, Rev. 1, ISFSI Maintenance Program
VY-EO-1, Rev. 2, ISFSI Emergency Plan Drills and Exercises
VY-EO-3, Rev. 5, ISFSI Emergency Plan Implementation
VY-EO-4, Rev. 4, ISFSI Response to Accident and Natural Phenomena Events
VY-OP-01, Rev. 5, ISFSI Log Sheet and Hi-Storm 100 Cask Heat Removal System Surveillance
Program
VY-OP-04, Rev. 1, ISFSI Hi-Storm and Pad Annual Inspection Program
VY-OP-18, Rev. 1, ISFSI Hi-Storm 100 Cask Temperature Monitoring System Maintenance
Miscellaneous
50.59 Pipe Removal for Trench to Main Stack
Annual Fire Department Training with Vermont Yankee, 2023
Annual Vermont Yankee Emergency Plan Training, 10/11/2023
Dose Summary by Company, 10/11/2023
Gamma Spectroscopy Reports SP-7173 and SP-7297
ISFSI Contaminated Injured Patient Drill, 10/17/23
Radioactive Waste Shipment NSVY-2023-135, 136, 231
Radioactive Waste Shipper Qualifications (2 sets)
Report of Analysis/Certificate of Conformance, 08/02/2023, 09/01/2023 Monitoring Wells
Survey Logbook 23: 0692, 0904
Vermont Yankee Nuclear Power Station, Fire Hazards Analysis, Rev. 23
Vermont Yankee Nuclear Power Station, Fire Brigade Pre-Fire Plans, Rev. 16
Work Packages and Plans
DEM-CWP-214, Rev. 2, Isolating Recirculation Piping at the Intake and Discharge Structures
DEM-TRWP-215, Rev. 2, Turbine Building Crane & Steel Structure Demolition
DRY-CWP-220, Rev. 0, Remove Piping and Components in Drywell
TUR-CWP-171, Rev. 7, Demo Prep in the Turbine Building - 2023
VY Routine Activity Item, Perform Annual Overpack and ISFSI Inspection, 6/19/2023.
LIST OF ACRONYMS USED
Agencywide Document and Access Management System
CFR
Code of Federal Regulations
Certificate of Compliance
Department of Transportation
IMC
Inspection Manual Chapter
GPO
Government Printing Office
Independent Spent Fuel Storage Installation
Northstar NDC
Northstar Nuclear Decommissioning Company, LLC
NRC
U.S. Nuclear Regulatory Commission
Post Shutdown Decommissioning Activities Report
Quality Assurance Program
Radiation Protection Technician
TS
Technical Specifications
Vermont Yankee Nuclear Power Station