IR 05000285/2023001
| ML23047A535 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 02/24/2023 |
| From: | Greg Warnick NRC/RGN-IV/DRSS/DIOR |
| To: | Via T Omaha Public Power District |
| Gersey L | |
| References | |
| IR 2023001 | |
| Download: ML23047A535 (13) | |
Text
February 24, 2023
SUBJECT:
FORT CALHOUN STATION - NRC INSPECTION REPORT 05000285/2023-001
Dear Troy Via:
This letter refers to the U.S. Nuclear Regulatory Commission (NRC) decommissioning inspection conducted February 6-9, 2023, at the Fort Calhoun Station near Blair, Nebraska.
The NRC inspectors discussed the results of the decommissioning inspection with members of your staff at the conclusion of the onsite inspection. The inspection results are documented in the enclosure to this letter.
The NRC inspection examined activities conducted under your license as they relate to public health and safety, the common defense and security, and compliance with the Commissions rules and regulations, and with the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observation of activities, and interviews with personnel. Specifically, the inspectors reviewed your decommissioning performance, safety reviews, and design changes. In addition, the inspectors performed a limited review of the solid radioactive waste management and radiation protection programs as they relate to greater-than-Class C waste. No violations were noted, and no response to this letter is required.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter, its enclosure, and your response if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response, if you choose to provide one, should not include any personal privacy or proprietary information so that it can be made available to the public without redaction. If you have any questions regarding this inspection report, please contact Linda Gersey at 817-200-1299, or the undersigned at 817-200-1249.
Sincerely, Signed by Warnick, Gregory on 02/24/23 Gregory G. Warnick, Chief Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Docket No. 050-00285 License No. DPR-40 Enclosure:
Inspection Report 050-00285/2023-001 Electronic Distribution via Listserv
ML23047A535 SUNSI ADAMS: Sensitive Non-Publicly Keyword Review By: Yes No Non-Sensitive Available NRC-002 LMG Publicly Available OFFICE DRSS/DIOR DRSS/DIOR C:DIOR NAME LMGersey SGAnderson GGWarnick SIGNATURE /RA/ /RA/ /RA/
DATE 02/21/23 02/21/23 02/24/23
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.: 050-00285 License No.: DPR-40 Report No.: 050-00285/2023-001 Licensee: Omaha Public Power District Facility: Fort Calhoun Station Location: 9610 Power Lane Blair, Nebraska Dates: February 6-9, 2023 Inspectors: Linda M. Gersey, Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Stephanie G. Anderson, Senior Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Accompanied By: Gregory G. Warnick, Chief Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Approved By: Gregory G. Warnick, Chief Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Enclosure
EXECUTIVE SUMMARY Fort Calhoun Station NRC Inspection Report 050-00285/2023-001 This U.S. Nuclear Regulatory Commission (NRC) inspection was a routine, announced inspection of decommissioning activities being conducted at the Fort Calhoun Station. In summary, the inspectors concluded that the licensee was conducting activities in accordance with site procedures, license requirements, and applicable NRC regulations.
Decommissioning Performance and Status Review at Permanently Shutdown Reactors The licensee was conducting decommissioning activities in accordance with license and regulatory requirements. The inspectors determined that the licensee was adequately controlling decommissioning activities and radiological work areas at the facility. Staffing levels were commensurate with the current facility activities. Decommissioning records were being maintained in accordance with regulatory requirements. The licensees decommissioning cost planning and schedule was being maintained without major deviations. (Section 1.2)
Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors The licensee was adequately maintaining a safety evaluation program associated to decommissioning changes and work activities. The processes for evaluating the safety impacts of facility changes and modifications were adequate for complying with the provisions of Title 10 Code of Federal Regulations (10 CFR) 50.59. The licensees 10 CFR 50.59 safety evaluation program provided training for personnel preparing, reviewing, and approving safety evaluations. (Section 2.2)
Solid Radioactive Waste Management and Transportation of Radioactive Materials The licensees contractor was conducting reactor vessel internal segmentation work involving greater-than-Class C waste in accordance with approved work plans and liner loading procedures. The contractor conducted waste management and transportation activities in accordance with the Post Shutdown Decommissioning Activities Report and site procedures. (Section 3.2)
Occupational Radiation Exposure at Permanently Shutdown Reactors The licensee had an effective radiation safety program to mitigate radiation exposures during the handling of greater-than-Class C waste. (Section 4.2)
Report Details Summary of Plant Status On June 24, 2016, Omaha Public Power District, the licensee, formally notified the NRC of its intent to permanently cease operations at Fort Calhoun Station (FCS) (Agencywide Documents Access and Management System [ADAMS] Accession No. ML16176A213). The licensee permanently ceased power operations on October 14, 2016, and certified pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.82(a)(1)(ii) that as of November 13, 2016, all fuel had been permanently removed from the FCS reactor vessel and placed into the spent fuel pool (ML16319A254).
The licensee submitted its Post-Shutdown Decommissioning Activities Report (PSDAR) to the NRC on March 20, 2017 (ML17089A759). The PSDAR described the licensees proposed decommissioning activities and schedule. At that time, the licensee selected the SAFSTOR decommissioning option. SAFSTOR is a method of decommissioning in which a nuclear facility is placed and maintained in a condition that allows the facility to be safely stored and subsequently decontaminated (deferred decontamination) to levels that permit release for unrestricted use.
In April 2019, the licensee changed its decommissioning approach from SAFSTOR to DECON.
DECON is a method of decommissioning in which structures, systems, and components that contain radioactive contamination are removed from the site and safely disposed at a commercially operated low-level waste disposal facility or decontaminated to a level that permits the site to be released for unrestricted use shortly after it ceases operation. By letter dated December 16, 2019, FCS submitted an updated PSDAR to reflect the change from SAFSTOR to DECON (ML19351E355).
On May 13, 2020, FCS removed the last canister of fuel and all special nuclear material from the spent fuel pool (ML20139A138). Accordingly, FCS entered the Independent Spent Fuel Storage Installation (ISFSI)-only Technical Specifications and Emergency Plan on May 18, 2020, and ISFSI-only Security Plan on June 24, 2020.
Title 10 CFR 50.82(a)(9) specifies that an application for license termination must be accompanied or preceded by a license termination plan (LTP). On August 3, 2021, FCS submitted its LTP to the NRC (ML21271A178). The NRC accepted the LTP for a detailed technical review on February 10, 2022 (ML22038A675). On July 13, 2022, the NRC held a public meeting at Blair Public Library & Technology Center and discussed the NRCs process and timeline for reviewing the LTP.
Since the previous inspection in December 2022, the licensee and contractors have continued with active decommissioning, including conducting final status surveys. Demolition was continuing with the auxiliary building drain lines and parts of the intake structure. Demolition work had reconvened at the turbine building after being suspended due to a change order request by the contractor. At the time of the inspection, the reactor vessel internal segmentation (RVI) had been completed. One cask of greater-than-Class C (GTCC) waste had been loaded and placed at the ISFSI. The second GTCC waste cask liner was being filled by the contractor.
Preparations were being made for the segmentation of the reactor vessel by contractors,
including installation of a ventilation filtration system. In addition, the licensee continued to ship radioactive waste to licensed disposal sites.
1 Decommissioning Performance and Status Review at Permanently Shutdown Reactors (Inspection Procedure 71801)
1.1 Inspection Scope The inspectors conducted interviews, attended licensee meetings, reviewed procedures, and conducted site tours to:
Evaluate the status of decommissioning and verify whether the licensee is conducting decommissioning activities in accordance with regulatory and license requirements; Maintain awareness of work activities to assess licensee control and conduct of decommissioning; Evaluate the licensee's decommissioning staffing, including that of the contracted workforce, to ensure that license requirements are met, as applicable to the current decommissioning status; and, Evaluate the status, progress, and changes that potentially impact decommissioning financial assurance.
1.2 Observations and Findings Section 2.0 of the updated PSDAR provides a general description of the planned decommissioning activities. The PSDAR states that decommissioning activities will be performed in accordance with written, reviewed, and approved site procedures. The inspectors reviewed selected decommissioning activities in progress, interviewed staff responsible for the work, and reviewed selected procedures and other related documents to ensure that decommissioning activities were being conducted as described in the PSDAR.
The inspectors attended several routine meetings during the inspection, including managements plan of the day and contractors start of shift meetings. Specifically, the inspectors attended the morning meetings for the Manafort contractor, the Energy Solutions radioactive waste group, the radiation protection staff, and the RVI support group. Staff attending the meetings were encouraged to voice any concerns and ask for clarification regarding the days work or other upcoming planned activities. The inspectors noted that safety was the first topic of discussion for every meeting attended.
The inspectors toured the facility, including containment, the containment waste structure (CWS), deconstruction areas, waste processing structure (WPS), ISFSI pad and ISFSI Operations Facility. In addition, the inspectors observed the contractors saw cutting the auxiliary building drains. While touring containment, the inspectors observed contractor staff loading the Radioactive Waste Canister (RWC) liner. The inspectors noted that radiation protection staff was present in the area during this work, performing
routine surveys of the area and performing decontamination of items and areas, as appropriate.
The radiation safety staff was appropriately assessing the potential in changes to the radiation areas due to the constant fluctuation of work activities in containment, the CWS, and the WPS. The inspectors did not identify any radiation area that was not already identified and posted by the licensee. General observations by the inspectors identified adequate housekeeping practices in all areas.
The inspectors evaluated staff levels for the licensee and onsite contractors. Staffing levels continue to fluctuate, depending on the decommissioning work in progress. The licensee discussed the staffing and training for the contractors who will be performing the upcoming segmentation of the reactor vessel. The inspectors determined that staffing levels were commensurate with the current facility activities and staffing needs for upcoming work was adequate.
Title 10 CFR 50.75(g) requires, in part, that the licensee keep records of information important to effective decommissioning. The inspectors verified that three condition reports, generated during 2022, had been included in this record. One condition report was related to a tank malfunction which resulted in low-level radioactive wastewater being released to the ground within a radiological restricted area. Two condition reports were related to small areas identified during final status surveys that were found to have contamination higher than background. The inspectors concluded that the licensee was maintaining the decommissioning records in accordance with regulatory requirements.
Title 10 CFR 50.71(e)(4), requires, in part, that the updated Defueled Safety Analysis Report (DSAR) be submitted to the NRC every 24 months. The licensee had submitted their updated DSAR on March 10, 2022, for NRC staff review (ML22081A040, ML22081A041, ML22081A042, ML22081A043, and ML22081A044). These updates are evaluated by NRCs program office staff. The inspectors verified that the licensee was submitting reports as required by 10 CFR 50.71.
Licensee decommissioning cost planning and assessment was evaluated by the inspectors in a meeting with senior licensee management. Attending this meeting was also a project manager from the NRC Financial Assurance Branch. The inspectors determined that the licensees cost planning and assessment were inclusive of current and planned major decommissioning activities as identified in the PSDAR. The inspectors also determined that licensee funding and expenditures were tracking as planned by the licensee with no significant deviations to expenditures or decommissioning schedule.
1.3 Conclusion The licensee was conducting decommissioning activities in accordance with license and regulatory requirements. The inspectors determined that the licensee was adequately controlling decommissioning activities and radiological work areas at the facility. Staffing levels were commensurate with the current facility activities. Decommissioning records were being maintained in accordance with regulatory requirements. The licensees decommissioning cost planning and schedule was being maintained without major deviations.
2 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors (Inspection Procedure 37801)
2.1 Inspection Scope The inspectors verified the licensees safety review process in accordance with the requirements of 10 CFR 50.59, Changes, tests, and experiments.
2.2 Observations and Findings The inspectors evaluated the licensees 10 CFR 50.59 safety evaluation program, as implemented by procedure FCSI-RA-203, 50.59 Review Process, revision 6. The inspectors also reviewed FCSI-RA-203-1, 50.59 Resource Manual, revision 4, which provided guidance for implementing the 10 CFR 50.59 process. Title10 CFR 50.59 allows a licensee to make changes to the facility or procedures and conduct tests or experiments without prior NRC approval. The inspectors determined that the procedures and work processes provided adequate quality instructions to assure proper implementation, review, and approval related to design changes, and activities of regulatory concerns involving decommissioning.
The inspectors assessed decommissioning and deconstruction activities including a review of one 10 CFR 50.59 screen and design change to ascertain whether the licensee appropriately utilized the 10 CFR 50.59 process. The design change reviewed by the inspectors allowed the licensee to update the existing licensing basis documentation and design basis to allow for GTCC storage within the ISFSI. No concerns were identified by the inspectors. The inspectors concluded that the licensee reviewed the activities under the 10 CFR 50.59 screening process in accordance with procedural and regulatory requirements.
The inspectors reviewed the licensees 10 CFR 50.59 safety evaluation program and confirmed that it provided effective periodic training for personnel responsible for preparing, reviewing, and approving safety evaluations. The inspectors reviewed the qualifications for the screeners, evaluators, reviewers, and the process owner to verify they were qualified and trained at the time of performing their job functions and found them to be adequate.
2.3 Conclusion The licensee was adequately maintaining a safety evaluation program associated to decommissioning changes and work activities. The processes for evaluating the safety impacts of facility changes and modifications were adequate for complying with the provisions of 10 CFR 50.59. The licensees 10 CFR 50.59 safety evaluation program provided training for personnel preparing, reviewing, and approving safety evaluations.
3 Solid Radioactive Waste Management and Transportation of Radioactive Material (Inspection Procedure 86750)
3.1 Inspection Scope
The inspectors conducted interviews, reviewed procedures, and conducted site tours to verify the licensee had an effective program for processing, handling, storage, and transportation of GTCC waste.
3.2 Observations and Findings Section 2.2.1 of the PSDAR states that the reactor vessel internals will be removed from the reactor vessel and segmented as necessary to separate the GTCC waste. The GTCC waste will be placed in containers similar to the spent fuel canisters for dry storage at the onsite ISFSI until it is accepted by the U.S. Department of Energy and transferred to an off-site facility. The inspectors reviewed the status of the GTCC work.
The licensee developed plans for the two GTCC RWCs that were filled with GTCC material. The reactor vessel internals were segmented in accordance with approved cutting plans. The material containing GTCC was segregated from the rest of the material.
At the time of the inspection, one GTCC RWC had been transferred to the ISFSI pad in early January 2023. The second RWC liner was in the reactor cavity, being filled with medium-sized GTCC pieces by the contractor. In addition, the small GTCC chips at the bottom of the reactor cavity were being vacuumed into tri-nuc filters, which will also be placed into the RWC liner. Once filled, the RWC liner will be placed into the RWC cask and moved to the ISFSI pad. The inspectors concluded that the licensees contractor was conducting work in accordance with approved segmentation work plans and liner loading procedures.
3.3 Conclusion The licensees contractor was conducting reactor vessel internal segmentation work involving GTCC material in accordance with approved work plans and liner loading procedures. The contractor conducted waste management and transportation activities in accordance with the PSDAR and site procedures.
4 Occupational Radiation Exposure at Permanently Shutdown Reactors (Inspection Procedure 83750)
4.1 Inspection Scope The inspectors conducted interviews, attended licensee meetings, reviewed procedures, and conducted site tours to verify the licensee was maintaining adequate protection of worker health and safety from exposure to radiation during the handling of GTCC waste.
4.2 Observations and Findings The inspectors attended start of shift meetings with licensee groups involved in the handling of GTCC waste. Discussions included mitigating potential radiation hazards during the vacuuming of chips in the reactor vessel and cavity by contract personnel and identifying radiation safety staff assigned to cover this work. The inspectors reviewed licensee procedure FCSD-RP-355, RWC Storage, revision 1, which describes radiological controls to be used during the loading, transfer, and storage of the RWC.
Procedure FCSD-RP-355 identifies the need for underwater surveys prior to removal of any items from the reactor cavity and verifying that the continuous air monitors are operable during the collection of GTCC waste. During the tour of containment, the inspectors observed the radiation safety staff monitoring the contractor collecting the GTCC waste in the reactor cavity. The radiation safety staff utilized appropriate instrumentation for performing gamma dose rate surveys and verifying radiation area postings were accurate. Interviews with the radiation safety staff verified that they were knowledgeable of the radiation safety hazards and were effectively communicating those hazards to contractors. The inspectors concluded that the licensee had an effective program to mitigate radiation exposures to workers during the handling of the GTCC waste.
4.3 Conclusion The licensee had an effective radiation safety program to mitigate radiation exposures during the handling of GTCC waste.
5 Exit Meeting Summary On February 9, 2023, the inspectors presented the final inspection results to the licensees staff. All proprietary information was returned to licensee representatives.
SUPPLEMENTAL INSPECTION INFORMATION KEY POINTS OF CONTACT Licensee Personnel A. Barker, Regulatory Assurance & Emergency Planning Manager A. Hanson, Principle Regulatory Specialist T. Maine, Plant Manager, Decommissioning J. Nowak, Project Manager, Decommissioning T. Uehling, Senior Director, FCS Decommissioning D. Whisler, Manager Radiation Protection & Chemistry INSPECTION PROCEDURES (IPs) USED IP 71801 Decommissioning Performance and Status Review at Permanently Shutdown Reactors IP 37801 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive Material IP 83750 Occupational Radiation Exposure at Permanently Shutdown Reactors LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened/Closed None Discussed None Attachment
LIST OF ACRONYMS 10 CFR Title 10 of the Code of Federal Regulations ADAMS Agencywide Documents Access and Management System CWS Containment Waste Structure DSAR Defueled Safety Analysis Report FCS Fort Calhoun Station GTCC Greater-than-Class C IP Inspection Procedure ISFSI Independent Spent Fuel Storage Installation LTP License Termination Plan NRC U.S. Nuclear Regulatory Commission PSDAR Post-Shutdown Decommissioning Activities Report RVI Reactor Vessel Internals RWC Radioactive Waste Canister WPS Waste Processing Structure 2