IR 05000285/2023006
| ML23354A283 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 12/21/2023 |
| From: | Greg Warnick NRC/RGN-IV/DRSS/DIOR |
| To: | Via T Omaha Public Power District |
| Evans R | |
| References | |
| IR 2023006 | |
| Download: ML23354A283 (12) | |
Text
December 21, 2023
SUBJECT:
FORT CALHOUN STATION - NRC INSPECTION REPORT 050-00285/2023-006
Dear Troy Via:
This letter refers to the inspection conducted on December 11-14, 2023, at your Fort Calhoun Station near Blair, Nebraska. The purpose of the inspection was to review decommissioning activities in progress at the site. The enclosed report presents the results of this inspection.
This inspection examined activities conducted under your license as they relate to public health and safety, the common defense and security, and to confirm compliance with the Commission's rules and regulations, and with the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel. Specifically, the inspectors reviewed decommissioning performance, radioactive waste management, and transportation of radioactive materials.
The results of the inspection were presented to members of your staff at the conclusion of the inspection on December 14, 2023. No violations were identified and no response to this letter is required.
In accordance with 10 CFR 2.390 of the NRC's "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 NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response 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, please contact Dr. Robert Evans, PhD, at 817-200-1234, or the undersigned at 817-200-1249.
Sincerely, Signed by Warnick, Gregory on 12/21/23 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 050-00285/2023-006 Electronic Distribution via ListServ
ML23354A283 SUNSI Review ADAMS: Sensitive Non-Publicly Available Keyword By: RJE Yes No Non-Sensitive Publicly Available NRC-002 OFFICE DRSS/DIOR DRSS/DIOR C:DIOR NAME REvans MJohnson GWarnick SIGNATURE /RA/ /RA/ /RA/
DATE 12/21/23 12/21/23 12/21/23
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.: 050-00285 License No.: DPR-40 Report No.: 050-00285/2023-006 Licensee: Omaha Public Power District Facility: Fort Calhoun Station Location: 9610 Power Lane Blair, Nebraska Dates: December 11-14, 2023 Inspectors: Robert J. Evans, PhD, CHP, PE, Senior Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security M. Troy Johnson, Senior Health Physicist 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 050-00285/2023-006 This U.S. Nuclear Regulatory Commission (NRC) inspection was a routine, announced inspection of decommissioning activities being conducted at Fort Calhoun Station. In summary, the inspectors concluded that the licensee and its decommissioning contractor were conducting activities in accordance with site procedures, license requirements, and applicable NRC regulations.
Decommissioning Performance and Status Review
- The licensee conducted decommissioning and maintenance 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 level and qualification were appropriate and commensurate with current decommissioning activities. No findings of significance were identified. (Section 1.2)
Solid Radioactive Waste Management and Transportation of Radioactive Materials
- The licensee and its decommissioning contractor conducted waste management and transportation activities in accordance with procedural instructions, Post-Shutdown Decommissioning Activities Report commitments, and regulatory requirements. No findings of significance were identified. (Section 2.2)
Report Details Summary of Plant Status Fort Calhoun Station permanently ceased power operations in 2016. In accordance with Title 10 to the Code of Federal Regulations (10 CFR) 50.82(a)(4), the licensee submitted a Post-Shutdown Decommissioning Activities Report (PSDAR) to the NRC in 2017. The PSDAR was revised in 2019 and 2020 (Agencywide Documents Access and Management System [ADAMS]
Accession Numbers ML19351E355 and ML21271A605). The PSDAR contains a description of the planned decommissioning activities along with a schedule for their accomplishment.
10 CFR 50.82(a)(9) specifies that an application for license termination must be accompanied or preceded by a license termination plan (LTP). The licensee submitted its proposed LTP to the NRC in August 2021. The NRC conducted an acceptance review and submitted two requests for additional information to the licensee. The licensee responded to the requests and subsequently submitted a revised LTP to the NRC on December 6, 2023 (ML23346A152).
At the time of the inspection, the licensee and its decommissioning contractor had completed the segmentation of the reactor vessel. The vessel components were shipped offsite for disposal except for the hemispherical bottom head assembly. The lockdown of containment was in progress to allow for future removal of large components and subsequent demolition of the containment structure. The contractor plans to remove the large components (pressurizer and steam generators) from containment in 2024.
During the onsite inspection, radiological assessment surveys and final decommissioning of the remaining auxiliary building structure were in progress. After remediation of the auxiliary building footprint is complete, the contractor plans to conduct final status surveys of the building surfaces. Other work planned for the near future include construction of a septic system for the training center to allow for dewatering and decommissioning of the onsite lagoons.
1 Decommissioning Performance and Status Review at Permanently Shutdown Reactors (Inspection Procedure 71801)
1.1 Inspection Scope The inspectors observed site activities, reviewed materials, and interviewed site personnel:
- To evaluate the status of decommissioning and verify whether the licensee was conducting decommissioning and maintenance activities in accordance with regulatory and license requirements.
- To maintain awareness of work activities to assess licensee control and conduct of decommissioning.
- To evaluate select licensee decommissioning staffing, personnel qualifications, and training requirements, including that of the contracted workforce, to ensure that license requirements were met, as applicable to the current decommissioning status.
1.2 Observations and Findings a. Status of Decommissioning The inspectors attended site status and Project Review Committee meetings and noted that the review, assessment, and scheduling of facility decommissioning, as well as problem identification were adequate. Additionally, inspectors discussed with licensee the status of decommissioning activities and noted them to be on schedule commensurate with challenges encountered.
The inspectors evaluated whether required maintenance was being conducted at an appropriate frequency and that preventative maintenance, as appropriate, was being performed and documented adequately to support decommissioning operations.
The inspectors reviewed the Independent Spent Fuel Storage Installation (ISFSI)
Emergency Preparedness Plan and noted it to be adequate.
b. Decommissioning Operations The inspectors performed plant tours including radiological control areas and containment to assess field conditions and decommissioning activities. Material condition of structures, systems, and components, housekeeping, system configurations, worker level of knowledge, as well as procedure use and adherence, were noted to be good relative to the status of decommissioning. The inspectors observed active remediation of the auxiliary building and noted the engineering controls in the work plans were appropriately implemented to protect the public and the environment.
The inspectors evaluated whether the licensee's organization and staffing were appropriately adjusted for changes in the status of decommissioning, specifically noted was the licensees cross qualification of final status survey staff with radiation protection staff to augment final status survey operations as the decommissioning process continues. The inspectors determined the licensee was taking appropriate staffing action to ensure reasonable assurance of safety and security in accordance with regulatory requirements and the license.
c. Decommissioning Staffing and Training The inspectors reviewed select radiation protection and transportation staff training records to determine if they were trained in accordance with license and regulatory requirements as well as verify that qualifications and training were current. No discrepancies were noted.
d. Problem Identification and Resolution The inspectors reviewed a sample of problems documented in the corrective action program and verified that the licensee had identified and implemented appropriate corrective actions.
1.3 Conclusion The licensee conducted decommissioning and maintenance 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 level and qualification were appropriate and commensurate with current decommissioning activities. No findings of significance were identified.
2 Solid Radioactive Waste Management and Transportation of Radioactive Materials (Inspection Procedure 86750)
2.1 Inspection Scope The inspectors observed site activities, reviewed documents, and interviewed site personnel to verify the effectiveness of the licensees programs for processing, handling, storage, and transportation of radioactive material.
2.2 Observations and Findings Section 2.2 of the PSDAR provides the licensees commitments for management and shipment of radioactive wastes. The inspectors reviewed the contractors waste management plan and associated implementing procedures, conducted site tours, and interviewed site staff to verify the effectiveness of the licensees waste management and shipment programs.
a. Radioactive Material Storage and Control Procedure FCSD-RW-PG-100, Waste Management Program, revision 0, provided the overarching plan for onsite waste management and shipment activities. Section 4.6 of the waste management program identified seven projected waste streams. During site tours, the inspectors noted that the licensees contractor appeared to be effectively managing these waste streams. For example, inventory sheets were being used to help keep track of wastes being added to containers. This information was needed, in part, for development of the shipment manifests. Physical barriers and administrative controls were also in place to help segregate the various waste streams.
As allowed by Section 4.7, construction and demolition wastes that were not radioactive may be disposed at an appropriate disposal facility that can accept these wastes. The licensee and its contractor disposed of demolition debris from the turbine building, intake structure, maintenance building, service building, old security building, and new warehouse as non-radioactive wastes. These structures were radiologically surveyed prior to demolition to demonstrate that the structures did not contain radioactive material above the release limits. Trucks containing these wastes were required to exit through the truck radiation monitoring system as a final check to ensure that the waste material did not contain measurable quantities of radioactive material. The inspectors observed trucks exiting the site through the truck portal monitor during the inspection with no abnormalities noted.
Section 4.16 provided the waste storage requirements. The inspectors randomly reviewed the storage of wastes at the site. The licensee and its contractor continued to maintain lists of storage locations and storage containers and conducted inspections of
these containers at 2-year intervals. The waste storage areas were being managed in accordance with site procedures.
b. Radioactive Waste Processing The licensees contractor was not processing wastes at the time of the inspection; therefore, this program area was not inspected.
c. Transportation of Radioactive Materials Section 4.24 of the waste management program provided the transportation requirements including requirements for shipping manifests. The contractor used industry-accepted software for development of the shipping papers. A waste broker demonstrated to the inspectors how the software worked, and the inspectors confirmed that shipping papers were being developed in accordance with the instructions provided in the applicable site procedure. Further, updates to the software were verified and validated in accordance with Section 4.19 of the waste management program.
Section 4.11 provided the waste container requirements. The inspectors compared the package containing the hemispherical bottom head assembly to the implementing procedure requirements for that type of package. The inspectors confirmed that the package met the general requirements provided in the site procedure.
Section 4.27 provided the requirements for development of status reports for project metrics. The contractor shared the projects metrics for 2023 with the inspectors. At the time of the inspection, the contractor had shipped approximately 300 shipments containing approximately 55 million pounds of radioactive waste material. Most wastes were bulk wastes containing concrete that were shipped by rail to a disposal site in Utah.
The predominant radionuclides in the shipped material included cobalt-60, iron-55, and nickel-63.
The inspectors reviewed the applicable site procedure that provided details for shipment of radioactive materials. The inspectors compared the instructions provided in the implementing procedure to two recently shipped loads of demolition debris. Based on the contractors records, the two shipments were made in compliance with U.S.
Department of Transportation (DOT) and procedural requirements.
The inspectors observed the contractor conducting receipt inspections of inbound railcars. The inspectors compared the observations to the guidance provided in the applicable site procedure. The inspectors also reviewed selected container receipt checklists and radiological surveys of recently received railcars. The checklists indicated that the containers did not require repairs upon arrival at the site, and the survey results indicated that the railcars met the criteria as empty containers.
Finally, Section 4.3 of the waste management program provided the training requirements. The inspectors confirmed that both the licensee and its decommissioning contractor had established electronic databases to manage the training of workers involved in the handling and shipment of radioactive wastes. The inspectors reviewed the training of a waste broker and confirmed that the individual had been trained including completion of function-specific training required by DOT regulations.
d. Problem Identification and Resolution The inspectors reviewed the status of the licensees and contractors corrective action programs for entries involving waste management and transportation activities. No significant problems were identified since the end of the last inspection of this program and the beginning of this inspection.
During the onsite inspection, the contractor had planned to ship the hemispherical bottom head assembly by rail to a disposal site in Utah. However, during the final radiological survey of the assembly, the contractor recognized that the package slightly exceeded the DOT-specified and procedural administrative limits for the package. The contractor postponed the shipment and conducted a thorough radiological survey of the package. In addition, a Condition Report (CR-2023-00211) was issued to determine the causes of the survey exceedances and to propose corrective actions to prevent recurrence of the incident. At the conclusion of the onsite inspection, the assembly was still onsite pending modification. The contractor planned to construct and install additional shielding on the assembly to reduce exposure rates to within regulatory and procedure requirements. The contractor plans to ship the hemispherical bottom head assembly after completion of these modifications and verification that the package complies with site procedure and DOT requirements.
2.3 Conclusion The licensee and its decommissioning contractor conducted waste management and shipping activities in accordance with procedural instructions, PSDAR commitments, and regulatory requirements. No findings of significance were identified.
3 Exit Meeting Summary The inspectors presented the final inspection results to members of the licensees staff at the conclusion of the inspection on December 14, 2023. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified except for certain decommissioning contactor procedures and documents which were marked as proprietary. The inspectors agreed to control the documents marked as proprietary to prevent accidental release of the material.
SUPPLEMENTAL INSPECTION INFORMATION KEY POINTS OF CONTACT Licensee and Contractor Personnel A. Barker, Regulatory Assurance & Emergency Planning Manager K. Daughenbaugh, ISFSI Shift Supervisor J. Emich, Waste Project Manager, EnergySolutions C. Fellman, Senior Human Capital Business Partner A. Hansen, Principal Regulatory Specialist C. Heimes, Manager ISFSI Site Security A. Kodra, License Termination Plan/Final Status Survey Project Manager, EnergySolutions J. Layton, Supervisor Outage Planning & Scheduling T. Maine, Plant Manager J. McBride, Lead Nuclear Oversight T. Mountain, Waste Broker, EnergySolutions J. Nowak, Project Director, EnergySolutions B. Pearson, Supervisor Radiation Protection A. Staebell, Manager Maintenance Services D. Weaver, Manager Project Controls INSPECTION PROCEDURES USED IP 71801 Decommissioning Performance and Status Review at Permanently Shutdown Reactors IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Open None Closed None Discussed None Attachment
LIST OF ACRONYMS ADAMS Agencywide Documents Access and Management System CFR Code of Federal Regulations DOT U.S. Department of Transportation IP Inspection Procedure ISFSI Independent Spent Fuel Storage Installation LTP License Termination Plan NRC Nuclear Regulatory Commission PSDAR Post-Shutdown Decommissioning Activities Report 2