IR 05000271/2025001
| ML25127A257 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 05/08/2025 |
| From: | Eve E Decommissioning, ISFSI, and Reactor Health Physics Branch |
| To: | Reid B Vermont Yankee |
| References | |
| IR 2025001 | |
| Download: ML25127A257 (1) | |
Text
May 8, 2025
SUBJECT:
NORTHSTAR VERMONT YANKEE, LLC, VERMONT YANKEE NUCLEAR POWER STATION, NRC INSPECTION REPORT NO. 05000271/2025001
Dear Billy Reid:
On March 31, 2025, 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 Commissions 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 April 17, 2025, and are described in the enclosed report.
Based on the results of this inspection, one violation of NRC requirements of no or relatively inappreciable (very low) safety significance (severity level IV) is documented in this report. For this violation, because of the significance and because the issue will be entered into your corrective action program, the NRC is treating the violation as a non-cited violation (NCV),
consistent with Section 2.3.2.a of the Enforcement Policy. If you contest the subject or severity of the NCV, you should provide a response within 30 days of the date of this letter, with the basis for your denial(s), to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region I; and the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.
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 Docket No.
05000271 License No.
DPR-28 cc w/encl:
Distribution via ListServ Enclosure:
Inspection Report 05000271/2025001 ELISE EVE Digitally signed by ELISE EVE Date: 2025.05.08 09:56:53 -04'00'
EXECUTIVE SUMMARY
Vermont Yankee Nuclear Power Station NRC Inspection Report No. 05000271/2025001
A routine announced decommissioning inspection was completed on March 31, 2025, 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.
List of Violations One NRC identified severity level IV non-cited violation (NCV) of Title 10 CFR 20.1101(a) is documented for the licensees failure to develop, document, and implement a radiation protection program. Specifically, NorthStar did not follow several radiation protection procedures which resulted in an unplanned intake.
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 January 13 - 15 and February 24 - 28, 2025, 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. The inspectors observed training related to extinguishing fires and how to operate a fire extinguisher.
Inspectors also reviewed the agreement with the offsite fire response.
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
The inspectors reviewed documentation and met with NorthStar management to discuss staffing, status of decommissioning and upcoming activities, among other topics to verify whether the licensee had conducted activities in accordance with regulatory and license requirements. The inspectors performed several plant walk-downs to assess field conditions and decommissioning activities by assessing material condition of structures, systems, and components, housekeeping, and system configurations. These walk-downs included all levels of the reactor building, drywell, and the solid radwaste storage area.
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 observed activities, reviewed documentation, and interviewed personnel associated with occupational radiation exposure to determine the adequacy of protection of worker health and safety. The inspectors conducted site walk-downs to check and assess radiological postings and control of radioactive material through personnel monitoring while exiting the radiological controlled area. The inspectors reviewed radiation work permits to determine if radiation work activities were pre-planned effectively to limit worker exposure. The inspectors reviewed radiation protection surveys conducted in the drywell in preparations for open air demolition.
b.
Observations
The inspectors verified radiological postings while conducting walk-downs and determined they were adequate. The inspectors determined the radiation surveys conducted post decontamination efforts were adequate for recordkeeping purposes. The inspectors noted that during this inspection period, radiation work permits reviewed were adequate for radiation work activities.
c. Conclusions
The inspectors identified one severity level IV non-cited violation of 10 CFR 20.1101(a),for the licensees failure to develop, document, and implement a radiation protection program commensurate with the scope and extent of licensed activities and sufficient to ensure compliance with the provisions of Part 20. Specifically, NorthStar did not properly follow several of their radiation protection procedures in the implementation of pipe cutting work activities in the reactor water clean-up heat exchanger room which resulted in an intake of radiological material and response to an airborne event.
On September 5, 2023, workers were removing piping from the reactor water clean-up heat exchanger room by cutting into the clean-up phase separator line overhead. The pipe had dose readings of 2R/hr. on contact. While they continued to make mechanical cuts on the line, a radiation protection technician noticed an increase in dose rates outside of the room and took a large area smear on the cart positioned outside of the room. The counted smear read 2,000cpm which prompted the technician to stop work and exit the radiological control area (RCA). All workers in the area had double anti-contamination clothing and a power air purifying respirator helmet. Once attempting to exit the RCA, two individuals could not clear the monitors and were then whole body counted for a suspected intake. After multiple whole body counts over the span of a few days, the two workers received an intake of less than 1 mrem committed effect dose equivalent (CEDE). Follow-up air sample analysis for the general air samplers outside of the room and inside of the room read 30 mrem/hr. and 6 mrem/hr., respectively. The floor was then posted as a contaminated area and was decontaminated prior to the completion of the activity.
Title 10 CFR 20.1703(c) requires licensees that assign or permit the use of respiratory protection equipment to limit the intake of radioactive material to implement and maintain a respiratory protection program that includes air sampling sufficient to identify the potential hazard and estimate doses. Radiation Work Permit (RWP) 2022-0405 Task 200 was the applicable RWP and task for this work activity and required one lapel air sample per crew when performing aggressive work on contaminated equipment.
NorthStar failed to implement the use of lapel air samples while performing mechanical cutting on contaminated piping in the reactor water clean-up heat exchanger room.
Title 10 CFR 20.1902(d) requires licensees to post airborne radioactivity areas, defined in 10 CFR 20.1003 as a room, enclosure or area in which airborne radioactive materials composed wholly or partly of licensed material, exist in concentrations in excess of the derived air concentrations (DACs) specified in Appendix B. NorthStar Procedure NSVY-RP-108, Radiation Protection Posting, Revision 0 step 5.1[3] states that when radiological conditions change, postings shall be updated and changes documented as soon as possible. NorthStar failed to post the reactor water cleanup heat exchanger room and surrounding areas after air samples, inside and outside the room, were identified to read 15 DAC-hr. and 2 DAC-hr., respectively.
10 CFR 20.1501(a) requires, in part, that each licensee make or cause to be made surveys that may be necessary for the licensee to comply with the regulations in 10 CFR Part 20 and are reasonable under the circumstances to evaluate the magnitude and extent of radiation levels and concentrations or quantities of residual radioactivity, and the potential radiological hazards of the radiation levels and residual radioactivity detected. NorthStar Procedure NSVY-RP-106-01, Radiological Survey Guidelines, Revision 1 step 5.2[12] states if work activities expose unsurveyed component surfaces, or allow access to unsurveyed areas, perform radiological surveys as appropriate to identify any changing conditions and communicate survey results to the workers involved in the work activity. NorthStar failed to perform radiological surveys as conditions changed when mechanically cutting into the cleanup phase separator line exposing powdered resin.
Title 10 CFR 20.1101(a) requires licensees to develop, document, and implement a radiation protection program commensurate with the scope and extent of licensed activities. NorthStar procedures related to radiation work permit, radiation protection posting, and radiological surveys listed above are used to implement a radiation protection program commensurate with the scope and extent of licensed activities and sufficient to ensure compliance with provisions of Part 20.
Contrary to the above, NorthStar failed to adequately implement a radiation protection program. Specifically, on September 5, 2023, the licensee did not follow procedures when mechanically cutting piping which led to an unplanned intake of less than 1mrem.
The significance of this violation was determined to be a severity level IV using Section 6.3.d of the NRC Enforcement Policy, dated August 23, 2024, regarding the failure to implement procedures, which has a very low safety significance. This determination was made because there was no spread of radioactive material to the public or environment and occupational dose impacts less than 1mrem.
Because this violation was determined to be of relatively inappreciable safety consequence, will be entered into the licensees corrective action program, and the violation was not willful or repetitive, this violation is being treated as a non-cited violation consistent with 2.3.2.a of the Enforcement Policy (NCV 05000271/2025001-001, Failure to implement a radiation protection program)
2.4 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 conducted walkdowns of radioactive waste labeling for packaged material.
b.
Observations
The inspectors determined that solid radioactive waste was adequately surveyed, stored, and monitored. The inspectors determined that packaged radioactive waste was labeled adequately to show the extent and magnitude of radioactivity and contamination levels.
c. Conclusions
No violations of more than minor significance were identified.
2.5 Inspection Procedure (IP) 40801 Problem Identification and Resolution at Permanently Shutdown Reactors
a. Inspection Scope
The inspectors assessed the implementation and effectiveness of NorthStars Corrective Action Program (CAP) by reviewing a sampling of issues, non-conformances, and any conditions adverse to quality that were entered into the CAP. The inspectors reviewed a representative selection of CAP documents to determine if a sufficiently low threshold for problem identification existed, if follow-up evaluations were of sufficient quality, and if NorthStar assigned timely and appropriate prioritization for issue resolution commensurate with issue significance. Additionally, the inspector interviewed site personnel responsible for the CAP program.
b.
Observations
The inspectors determined that most issues had been identified, entered into the CAP and evaluated commensurate with their safety significance through document review and discussion. The inspectors noted that one condition report (CR 2023000142) was incorrectly labeled as non-adverse when it should have been adverse. After discussions with site management, the inspectors note that this was the only condition report where it was incorrectly identified. The inspectors determined adequate and timely entries into the CAP and resolution.
Exit Meeting
Summary
On April 17, 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.
Partial List of Documents Reviewed
NSVY-RP-108, Radiation Protection Posting, Revision 0 NSVY-RP-106-01, Radiological Survey Guidelines, Revision 1 Radiation Work Permit 2022-0405 Condition Report 2023000142
SUPPLEMENTARY INFORMATION
ITEMS OPEN, CLOSED, AND DISCUSSED
Closed
Section
Summary
2.3. b