IR 05000271/2024002

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Northstar Vermont Yankee, LLC, Vermont Yankee Nuclear Power Station, NRC Inspection Report No. 05000271/2024002
ML25056A068
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
(DPR-028)
Issue date: 03/04/2025
From: Eve E
NRC Region 1
To: Reid B
Vermont Yankee
References
IR 2024002
Download: ML25056A068 (1)


Text

March 4, 2025

SUBJECT:

NORTHSTAR VERMONT YANKEE, LLC, VERMONT YANKEE NUCLEAR POWER STATION, NRC INSPECTION REPORT NO. 05000271/2024002

Dear Billy Reid:

On December 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection under Inspection Manual Chapter 2561, Decommissioning Power Reactor Inspection Program," at the 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 Billy Reid, Site Vice President and other members of your staff on January 29, 2025, 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 and 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 should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.

No reply to this letter is required. Please contact Storm Veunephachan of my staff at 610-337-5366 if you have any questions regarding this matter.

Sincerely, Elise Eve, Team Leader Decommissioning Team Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Radiological Safety and Security

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION I

475 ALLENDALE ROAD, SUITE 102 KING OF PRUSSIA, PA 19406-1415 ELISE EVE Digitally signed by ELISE EVE Date: 2025.03.04 08:53:34 -05'00' Docket No.

05000271 License No.

DPR-28

cc w/encl:

Distribution via ListServ

Enclosure:

Inspection Report 05000271/2024002

ML25056A068

OFFICE

DRSS/RI

DRSS/RI

NAME SVeunephachan/sv EEve/ee

DATE 03/04/2025 03/04/2025

Enclosure

U.S. NUCLEAR REGULATORY COMMISSION INSPECTION REPORT

Docket Nos.

05000271

License No.

DPR-28

Report No.

2024002

Licensee:

NorthStar Vermont Yankee, LLC (NorthStar)

Facility:

Vermont Yankee Nuclear Power Station (VY)

Location:

Vernon, VT 05354

Inspection Dates:

July 1, 2024 - December 31, 2024

Inspectors:

Harry Anagnostopoulos, Senior Health Physicist

Decommissioning, ISFSI, and Reactor Health Physics Branch

Division of Radiological Safety and Security

Storm Veunephachan, Senior Health Physicist

Decommissioning, ISFSI, and Reactor Health Physics Branch

Division of Radiological Safety and Security

Approved By:

Elise Eve, Team Leader

Decommissioning Team

Decommissioning, ISFSI, and Reactor Health Physics Branch

Division of Radiological Safety and Security

EXECUTIVE SUMMARY

NorthStar Vermont Yankee, LLC

Vermont Yankee Nuclear Power Station NRC Inspection Report No. 05000271/2024002

A routine announced decommissioning inspection was completed on December 31, 2024, at Vermont Yankee (VY). The inspection included a review of the fire protection program, decommissioning performance, occupational radiation exposure and control, radiological surveys to support a license termination plan, environmental monitoring, effluent release monitoring and assessment, and the transportation of radioactive waste for disposal. The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records, and site walk-downs. The U.S. Nuclear Regulatory Commissions (NRCs) program for overseeing the safe decommissioning of a permanently shut-down 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

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 Category 3, Decommissioning (DECON), No Fuel in the Spent Fuel Pool as described in IMC 2561.

2.0 Active Decommissioning Performance and Status Review

The inspectors performed on-site decommissioning inspection activities on August 19 - 22 and November 18 - 21, 2024, supplemented by in-office reviews and periodic phone calls. The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records, and site walk-downs.

2.1 Inspection Procedure (IP) 64704 Fire Protection Program at Permanently Shutdown Reactors

a. Inspection Scope

The inspectors reviewed the Vermont Yankee Nuclear Power Station Fire Hazards Analysis, Revision 24 and toured the reactor building to confirm that NRC commitments and requirements were being met. The inspectors examined the smoke detection system for the reactor building elevator and the portable fire extinguishers which were staged throughout the reactor building as part of the incipient fire brigade fire response strategy. The inspectors reviewed existing agreements with local fire response agencies for the provision of an offsite response (if needed).

While touring the reactor building, the inspectors confirmed that administrative controls were in place for the use and storage of combustible materials in a manner which minimizes the occurrence of fire, and that hot work activities were controlled in accordance with NorthStar procedures and the associated hot work permits. The inspectors observed that fire watches were assigned to hot work activities as expected.

b. Observations and Findings

The inspectors observed that there were no active fire suppression systems remaining in the reactor building and that the only fire detection system consisted of smoke detectors for the reactor building elevator. Fire response was found to be a combination of immediate onsite response with portable fire extinguishers followed by an offsite response should it be needed. These findings were as expected considering the decommissioning status of the building, which is approaching a readiness for demolition.

The inspectors noted that the use and storage of combustible materials in the reactor building was strictly minimized and that packaged radioactive materials were being promptly removed. The inspectors found that portable fire extinguishers were plentiful and readily available in the reactor building and near hot work activities.

c. Conclusions

No violations of more than minor significance were identified.

2.2 Inspection Procedure (IP) 71801 Decommissioning Performance and Status Reviews at Permanently Shutdown Reactors

a. Inspection Scope

Major decommissioning activities accomplished during the inspection period included:

  • Completed the removal of remaining nuclear and nuclear support systems and components from the reactor building
  • Prepared the circulating water discharge structure for radiological surveys
  • Continued decontamination of the reactor building in support of open-air demolition

b.

Observations

The inspectors noted that while touring the reactor building, torus room, and dry well the material condition and housekeeping were adequate.

c. Conclusions

No violations of more than minor significance were identified.

2.3 Inspection Procedure (IP) 83750 Occupational Radiation Exposure at Permanently Shutdown Reactors

a. Inspection Scope

The inspectors walked-down the reactor building to observe NRC-required radiological area postings and the labeling of radioactive materials. The inspectors toured outdoor areas to determine whether the storage of radioactive materials met NRC requirements for security and identification. The inspectors walked-down the sites radiologically controlled area boundary to establish whether radiological boundaries and radiological postings met NRC requirements. The inspectors observed the removal of underground piping and toured the site effluent outfall structure with NorthStar staff to discuss their plans for removal of structures and for associated post-removal radiological surveys.

The inspectors reviewed a sampling of condition reports that were related to the sites radiation protection program.

b.

Observations

The inspectors verified radiological postings while conducting walkdowns through the reactor building. These walkdowns included tours of the drywell, torus room, and all general area elevations of the reactor building. The inspectors verified that the Radiological Controlled Area (RCA) is posted in accordance with site procedures and regulations. The inspectors note that due to the size of the RCA, there are frisking stations implemented to ensure licensee personnel to have water breaks and rest areas outside of the reactor building while remaining inside the RCA. The inspectors observed workers exiting the RCA and verified workers adhering to site procedures. The inspectors determined that the licensee performance of source and calibration checks were adequately performed, and the staff conducting these activities was sufficiently knowledgeable of the instruments and site procedures. The inspectors reviewed gamma spectroscopy control charts and energy calibrations while interviewing licensee personnel. The inspectors determined that the licensee performance of gamma spectroscopy is adequate.

During a routine review of condition reports, the inspectors performed a preliminary review of the event described in CR 2023000142, Contamination during piping removal dated 9/6/2023. The inspectors determined that further inspection of the circumstances of the event was warranted. The inspectors requested additional supporting documentation from NorthStar, and an open item was created to track the NRCs continued review of the issue (Open Item 05000271/2024002-01, Continued Review of Contamination Event).

c. Conclusions

No violations of more than minor significance were identified.

2.4 Inspection Procedure (IP) 83801 Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors

a. Inspection Scope

The inspectors reviewed the Analysis in Preparation for the Open-Air Demolition of Vermont Yankees Advanced Off-Gas Building, RSCS Technical Support Document No.20-050, dated August 24, 2020. This document contains the technical basis for the radiological criteria that NorthStar intends to meet prior to open-air demolition of various radiologically involved buildings, including the reactor building (the focus of their current work).

The inspectors reviewed work package DEM-TRWP-177, Demolition of the Containment Access Building and Reactor Building Airlock, dated December 19, 2022, in order to assess to process to be followed and the documentation which will be created by NorthStar when the reactor building is demolished.

The inspectors reviewed the VY Characterization Survey Planning Worksheet, survey unit number DISC01-01 Discharge Structure, dated May 31, 2023. This document contains the radiological survey unit classification and radiological survey design that will be used to determine whether the discharge structure may be released from radiological controls, partially demolished, and backfilled with earth as part of the routine decommissioning process. This work is to be performed by NorthStar at risk because they do not yet have an approved license termination plan. The inspectors reviewed the plans, conducted a walk-down of the discharge structure, and discussed the plans with the NRC decommissioning project manager for Vermont Yankee in an effort to assure that this at risk work will likely meet NRC requirements when the license termination plan is issued for the site.

The inspectors interviewed the NorthStar Final Status Survey Lead Engineer regarding NorthStars plans for final status survey of the site and the current status of the license termination plan. The inspectors reviewed a selection of NorthStars final status survey procedures, including the Site Closure-Characterization-Final Status Survey Quality Assurance Project Plan, NSVY-FS-002, Revision 0.

b.

Observations

The inspectors confirmed that the radiological criteria for open air demolition contained a reasonable technical basis. The inspectors noted that the survey plan for the discharge structure identified the structure as a Class 3, that this classification was adequately supported by the historical site assessment, and that the survey design appeared to be appropriate for this classification. The inspectors established that the NorthStar Final Status Survey Lead Engineer was experienced in the development, execution, and evaluation of final status surveys and that the quality assurance plan for these surveys was comprehensive.

c. Conclusions

No violations of more than minor significance were identified.

2.5 Inspection Procedure (IP) 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring

a. Inspection Scope

The inspectors reviewed the Vermont Yankee Nuclear Power Station Off-Site Dose Calculation Manual, Revision 42 and the Process Control Program, (NSVY-RW-105),

Revision 2 to confirm that their implementation met NRC requirements.

The inspectors performed a walk-down of effluent sampling systems for the reactor building to evaluate their configurations and to establish that they functioned as required.

The inspectors reviewed a sampling of air effluent calculations and independently verified two effluent estimates.

The inspectors reviewed the 2023 Radiological Effluent Release Report (dated May 5, 2024) and the 2023 Radiological Environmental Operating Report, dated May 9, 2024, to establish that they were submitted as required and that any anomalous results, unexpected trends, or abnormal releases identified were investigated, entered into the corrective action program, and adequately resolved.

The inspectors reviewed the implementation of the radiological environmental monitoring program and visited a selection of air sampling stations and thermoluminescent dosimeter monitoring stations to establish whether the stations met requirements and were capable of collecting representative samples of the environs surrounding the decommissioning site.

The inspectors reviewed the implementation and results of groundwater monitoring wells which were established during plant operation as part of an industry voluntary Groundwater Protection Initiative.

For the analysis of environmental samples, the inspectors confirmed that NorthStar uses a vendor laboratory which has an acceptable quality control program, and which participates in an inter-laboratory comparison program.

b.

Observations

The inspectors observed that NorthStar had four air-effluent release points from the reactor building. Three of the release points consisted of constructed openings in the building that were established to remove the smoke from demolition cutting and other hot work. The openings were provided with a large fan and a bank of high efficiency air particulate filters to remove particles from the airstream before release to the outdoor environment. The inspectors noted that these filters had not been performance tested to ensure that the filter media was intact and did not exhibit bypass flow. The inspectors requested and observed the conduct of removable contamination surveys by NorthStar in the exhaust plenums of these systems, which confirmed that no radioactive contamination had inadvertently bypassed the filters.

While examining the placement of thermoluminescent dosimeters at environmental monitoring stations, the inspectors identified that the dosimeters were frequently surrounded by vegetation, placed on fencing, or otherwise emplaced in a manner which might negatively affect the results. The inspectors discussed the relevant industry standards with NorthStar personnel, who corrected the deficiencies during the inspection period.

c. Conclusions

No violations of more than minor significance were identified.

2.6 Inspection Procedure (IP) 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials

a. Inspection Scope

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 packaged radioactive material being transferred from the reactor building to the waste loadout area to evaluate if the licensee had properly classified and stored radioactive materials. The inspectors observed personnel surveying the packaged radioactive material before storing in the waste loadout area. The inspectors reviewed the Part 37 security plan and reviewed Vermont Yankees implementation of the requirements. The inspectors reviewed the sealed source inventory and conducted onsite walkdowns of sealed source locations.

The inspectors reviewed three radioactive material transportation packages to establish that the material had been appropriately characterized, classified, and prepared in accordance with federal regulations and site procedures.

The inspectors reviewed the Vermont Yankee process control program to confirm that solid waste processing methods agreed with the descriptions in the Decommissioning Safety Analysis Report.

b.

Observations

The inspectors determined that solid radioactive waste was adequately surveyed, stored, and monitored. The inspectors conducted walkdowns to verify the locations of sealed sources and determined they were stored and handled according to regulations.

The inspectors determined that Vermont Yankee adequately implemented their Part 37 security plan.

c. Conclusions

No violations of more than minor significance were identified.

Exit Meeting

Summary

On January 29, 2025, the inspectors presented the inspection results to Billy Reid, Site Vice President, and other members of NorthStar organization. No proprietary information was documented in this report.

SUPPLEMENTARY INFORMATION

ITEMS OPEN, CLOSED, AND DISCUSSED

Opened

Section

Summary

05000271/2024002-01

2.3. b

Continued Review of Contamination Event