IR 05000271/2024001
| ML24169A222 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 06/28/2024 |
| From: | Anthony Dimitriadis Decommissioning, ISFSI, and Reactor Health Physics Branch |
| To: | Reid B NorthStar Nuclear Decommissioning Company |
| References | |
| IR 2024001 | |
| Download: ML24169A222 (1) | |
Text
June 28, 2024
SUBJECT:
NRC INSPECTION REPORT NO. 05000271/2024001, NORTHSTAR NUCLEAR DECOMMISSIONING COMPANY, LLC, VERMONT YANKEE NUCLEAR POWER STATION, VERNON, VERMONT
Dear Billy Reid:
On June 8, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an on-site 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 February 26-29, April 15-18, and May 20-23, 2024.
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 Commissions rules and regulations and the conditions of your license.
The inspection consisted of observations by the inspectors, interviews with personnel, and a review of procedures and records. The results of the inspection were discussed with you and other members of the VY staff on June 11, 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 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).
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 me at 610-337-6953 if you have any questions regarding this matter.
Sincerely,
/for/
Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Radiological Safety and Security
Docket Nos.
05000271 License No.
Enclosure: Inspection Reports 05000271/2024001
cc w/encl: Distribution via ListServ
MARK HENRION Digitally signed by MARK HENRION Date: 2024.06.28 13:07:55 -04'00'
EXECUTIVE SUMMARY
Northstar Nuclear Decommissioning Company, LLC
Vermont Yankee Nuclear Power Station NRC Inspection Report No. 05000271/2024001
An announced Vermont Yankee Nuclear Power Station (VY) decommissioning inspection was completed on June 8, 2024. On-site inspections were performed February 26-29, April 15-18, and May 20-23, 2024. Additional inspection activities (in office reviews) were conducted remotely during the inspection period. The inspection included a review of plant modifications, problem identification and resolution, decommissioning performance and status, and occupational exposure. The inspection consisted of observations by the inspectors, interviews with VY personnel, a review of procedures and records, and plant walk-downs. The NRCs program for overseeing the safe operation 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 findings of 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 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 Nuclear Decommissioning Company, LLC (Northstar NDC) (ADAMS Accession No. ML18347B360). VY is in active decommissioning as described in IMC 2561.
2.0 Active Decommissioning
a. Inspection Scope
(Inspection Procedures 37801, 40801, 71801, 83750)
The inspectors conducted document reviews and interviews with plant personnel to verify Northstar NDC procedures and processes conformed to 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 is needed and reviewed the 10 CFR 50.59 screening for the abandonment of the fire suppression water system. 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 NDCs management performed audits and surveillances 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 NDC assigned timely and appropriate prioritization for issue resolution commensurate with the significance of the issue. The inspectors reviewed site audit schedules and surveillances from the past year to determine if they were thorough and that corrective actions were initiated if necessary. The inspectors interviewed the Employee Concerns Representative to gain insights on the status of the licensees safety culture at VY.
The inspectors attended licensee meetings, including plan of the day meetings, integration 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 a walk-down of the site and evaluated housekeeping and assessed area radiological conditions and radiological access controls, including posting and labeling. The inspectors observed current work activities including removal of reactor building piping and components, legacy rotor segmentation, and excavation of contaminated soil 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 reviewed documentation and met with staff and management to discuss organization and staffing, training and qualifications, status of decommissioning and upcoming activities, among other topics to verify whether the licensee is conducting activities in accordance with regulatory and license requirements. The inspectors reviewed the status of the decommissioning trust fund and met with Northstar NDC management to discuss annual expenditures.
The inspectors observed activities, reviewed documentation, and interviewed personnel associated with occupational radiation exposure to evaluate the licensees protection of worker health and safety. The inspectors reviewed the qualifications of select individuals in the Radiation Protection (RP) organization to determine if they met site requirements.
The inspectors conducted site walk-downs, including radiologically controlled areas, to examine and verify radiological postings, airborne and contamination controls, and locked high radiation doors and gates. The inspectors reviewed Radiation Work Permits (RWPs), and work plans to determine if radiation work activities were pre-planned effectively to limit worker exposure. The inspectors observed RPTs perform work activities to determine if implementation of radiological work controls, training and skill level were sufficient for the activities being performed. The inspectors reviewed the site dosimetry program and radiological dose records to verify compliance with the regulations and toured instrument and sealed source storage locations to verify the adequacy of radiological instrumentation.
b. Observations and Findings
The inspectors determined that 10 CFR 50.59 screenings are being performed and that Northstar NDC has trained and qualified individuals to perform the screenings and evaluations. The inspectors determined that no changes or modifications requiring NRC approval were made in the past year.
The inspectors determined that issues were being 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 audits and surveillances were being performed by qualified individuals independent of the organization being audited and that management reviewed the audits and associated corrective actions. The inspectors did not identify any safety conscious work environment concerns.
The inspectors noted management maintains a high level of engagement regarding all aspects of the project and worker safety is 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 RPTs effectively maintained radiological controls for the work-in-progress. The inspectors determined staffing is appropriate for the current stage of decommissioning and training programs were being appropriately implemented, and managers verified staff training qualifications on a regular basis. The inspectors verified the activities, schedule, and trust fund expenditures were consistent with license requirements, TS, and the site PSDAR.
The inspectors verified that RWPs and site work plans were implemented and were effective in limiting worker exposure, and occupational dose was appropriate for the scope of the radiological activities performed. The inspectors determined that RP staff effectively controlled work activities, survey records were clear and complete, appropriate instruments were used, and staff performed adequate instrument source checks. The inspectors determined RP staffing was adequate for the work activities being conducted and determined that the RP staff met site qualification requirements.
The inspectors noted an appropriate level of worker and supervisor knowledge of protective clothing and respirator donning and doffing and continuous coverage by an RPT during decommissioning activities in the reactor building. The inspectors determined that occupational radiation protection issues were entered into the CAP at an appropriate threshold and appropriate corrective actions were taken. The inspectors determined the site dosimetry program was adequate and worker exposures were within regulatory limits.
c. Conclusions
Based on the results of this inspection, no findings of safety significance were identified.
3.0
Exit Meeting Summary
On June 11, 2024, the inspectors presented the inspection results to Billy Reid, Vice President, and other members of Northstar NDC staff who acknowledged the inspection results. The inspectors verified that no proprietary information was retained or documented in this report.
PARTIAL LIST OF PERSONS CONTACTED
Licensee B. Reid, Vice President D. Pearson, Vice President C. Daniels, ISFSI Senior Manager S. Dorval, QA Manager M. Hill, Radiation Protection Technician S. Hill, ECO Coordinator N. Langub, Decommissioning Director A. Miller, Radiation Protection Manager D. Miller, ISFSI Administrator C. Mulverhill, Facility Area Manager S. Naeck, ISFSI Operations Manager F. Provencal, Structure Demolition Manager T. Silko, Licensing Manager L. Smith, Radiation Protection Technician D. Toegel, Decommissioning Project Manager J. Ward, Facility Maintenance Coordinator G. Wood, LTP/FSS Lead Engineer
State of Vermont T. Leshinskie, Nuclear Engineer
ITEMS OPEN, CLOSED, AND DISCUSSED
None
LIST OF
DOCUMENTS REVIEWED
Audits and Reports
QS-VY-23-001, Surveillance of Post LTP Submittal and Final Status Survey Activities
Vermont Yankee Fire Hazards Analysis, Rev. 24
VY-A-23-01, Site Audit, ISFSI Operations and Radiological Programs
Condition Reports
CR-2023-0143, 0165; 2024-0006, 0012, 0039; 2024-0006, 0012, 0017, 0045
Procedures and Programs
NSVY-RP-101, Plant Access Control for Radiologically Controlled Areas, Rev. 0
NSVY-RP-105, Radiological Work Permits (RWP), Rev. 0
NSVY-RP-106, Radiological Survey Documentation, Rev. 1
NSVY-RP-106-1, Radiological Survey Guidelines, Rev. 1
NSVY-RP-108, Radiation Protection Posting, Rev. 0
NSVY-RP-131, Air Sampling, Rev. 2
NSVY-RP-141, Job Coverage, Rev. 0
NSVY-RP-201, Dosimetry Administration, Rev, 0
NSVY-RP-202, Personnel Monitoring, Rev. 0
NSVY-RP-203, Dose Assessment, Rev. 1
NSVY-RP-204, Special Monitoring Requirements, Rev. 0
NSVY-RP-206, Dosimeter of Legal Record Quality Assurance, Rev. 0
NSVY-RP-208, Whole Body Counting/In-Vitro Bioassay, Rev. 1
NSVY-RP-301, Radiation Protection Instrument Control, Rev. 0
NSVY-RP-303, Source Checking of Radiation Protection Instrumentation, Rev. 0
NSVY-RP-501, Respiratory Protection Program, Rev. 0
NSVY-RP-4558, Calibration of Ion Chamber Survey Meters, Rev. 0
NSVY-RP-4590, Passive Whole-Body Counting, Rev. 0
NSVY-TRNRP-006, Radiation Protection Contract Technician Requirements, Rev. 1
NSVY-WC-001, Integrated Work Control Program, Rev. 6
VY-AD-7, Corrective Action Program, Rev. 4
VY-AD-9, Process Applicability Determination Process and Regulatory Reviews, Rev. 3
VY-AD-30, ISFSI Nuclear Safety Culture, Rev. 2
Miscellaneous
GET/GRT Training Presentation
NVLAP Accreditation, Landauer, Inc.
Organization Charts, April 2024
50.59 Screenings; Abandon Fire Suppression Water System, FSS Procedures
RWP 2024-0405
Vermont Yankee Integrated Oversight Schedule for 2024
Vermont Yankee Quality Assurance Program, Rev. 9
Waste shipment package NSVY-2024-22
Work Packages and Plans
TOR-CWP-244, Torus Decon and Demo Prep
DRY-CWP-220, Remove Piping and Components in Drywell
LIST OF ACRONYMS USED
Agencywide Document and Access Management System
Corrective Action Program
CFR
Code of Federal Regulations
GPO
Government Printing Office
IMC
Inspection Manual Chapter
Northstar NDC
Northstar Nuclear Decommissioning Company, LLC
NRC
U.S. Nuclear Regulatory Commission
Post Shutdown Decommissioning Activities Report
Radiation Protection
Radiation Protection Technician
Radiation Work Permit
TS
Technical Specifications
Vermont Yankee Nuclear Power Station