IR 05000285/2024003
| ML24297A338 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 10/29/2024 |
| From: | Jeffrey Josey NRC Region 4 |
| To: | Via T Omaha Public Power District |
| References | |
| IR 2024003 | |
| Download: ML24297A338 (1) | |
Text
October 29, 2024
SUBJECT:
FORT CALHOUN STATION-NRC INSPECTION REPORT 050-00285/2024-003
Dear Troy Via:
This letter refers to the U.S. Nuclear Regulatory Commission (NRC) decommissioning inspection conducted October 7-10, 2024, 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, final status surveying, radwaste treatment, effluent and environmental monitoring. 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 Christian Dennes at 817-200-1529 or the undersigned at 817-200-1249.
Sincerely, Jeffrey E. Josey, Chief Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Docket No. 050-00285 License No. DPR-40 Enclosure:
Inspection Report 050-00285/2024-003 Electronic Distribution via Listserv Signed by Josey, Jeffrey on 10/29/24
ML24297A338 SUNSI Review By:CRD2 ADAMS:
Yes No Sensitive Non-Sensitive Non-Publicly Available Publicly Available Keyword NRC-002 OFFICE DRSS/DIOR DRSS/DIOR DRSS/DIOR C:DRSS/DIOR NAME CDennes REvans SGAnderson JEJosey SIGNATURE
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DATE 10/23/2024 10/24/2024 10/24/2024 10/29/2024
Enclosure U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.
050-00285 License No.
DPR-40 Report No.
050-00285/2024-003 Licensee:
Omaha Public Power District Facility:
Fort Calhoun Station Location:
9610 Power Lane Blair, Nebraska Dates:
October 7-10, 2024 Inspectors:
Robert J. Evans, PhD, PE, CHP, Senior Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Christian R. Dennes, Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Approved By:
Jeffrey E. Josey, Chief Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Attachment:
Supplemental Inspection Information
EXECUTIVE SUMMARY Fort Calhoun Station NRC Inspection Report 050-00285/2024-003 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
The inspectors observed decommissioning work in progress and concluded that the work was being conducted with an emphasis on industrial and radiological safety. Critical positions in the organizational structure were staffed. The licensee continued to identify problems and implement its corrective action program in accordance with quality assurance program requirements. (Section 1.2)
Inspection of Remedial and Final Surveys
The licensees final status survey program was being implemented in accordance with license termination plan requirements. The licensee continued to identify problems in this program area and implement corrective actions for these problems. (Section 2.2)
Radioactive Waste Treatment, and Effluent and Environmental Monitoring
In accordance with the license termination plan, the licensee established procedural and radiological controls for the environmental monitoring program. The inspectors reviewed the licensees environmental monitoring equipment and observed implementation of sampling procedures. Additionally, the licensee effectively implemented the liquid effluent storage and treatment system consistent with the offsite dose calculation manual. (Section 3.2)
Report Details Summary of Site 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)(9), an application for a license termination must be accompanied or preceded by the 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 subsequently submitted a revised LTP to the NRC in December 2023 (ML23346A152).
The NRC approved the LTP by license amendment dated January 31, 2024 (ML24019A167).
Since the previous inspection, the licensee shipped steam generator B and the reactor coolant pumps for offsite disposal. The security access facility was secured for future radiological survey and demolition. Final status surveys were essentially complete in selected land areas, building drains, and the stressing gallery.
During the inspection, the licensee continued to decommission the interior of containment. The waste material, including radioactive debris and piping, was being transferred to the waste processing structure for preparation for shipment to a disposal site. In addition, the licensee continued to conduct radiological assessments, remedial action support surveys, and final status surveys at several locations around the site. The licensee was also cleaning portable water storage tanks for future release from the site.
Decommissioning Performance and Status Reviews at Permanently Shutdown Reactors (IP 71801)
The inspectors observed site activities, reviewed selected records, 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.
- Maintain awareness of work activities to assess licensee control and conduct of decommissioning.
- 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 conducted site tours, in part, to observe decommissioning activities in progress. Inside containment, heavy equipment continued to demolish the floor and walls. At the time of the inspection, demolition activities were being conducted below ground level. The piping, concrete rubble, and other debris were being staged in the adjacent containment waste structure. The material was loaded into dump trucks at the containment waste structure for transfer to the waste processing structure. Inside the waste processing structure, the debris was loaded into railcars for shipment to an out-of-state disposal site. The inspectors noted good health physics and industrial safety controls in all locations. Outside of containment, work in progress included radiological
surveys of various areas around the site. The surveys were being conducted in accordance with the instructions provided in Section 5 of the LTP.
b.
Decommissioning Operations The inspectors conducted a detailed review of the licensees airborne radiological controls used monitor for potential inhalation doses to site workers. The licensee used three levels of air sampling to monitor worker exposure to airborne radioactivity. The first level was breathing zone samplers. This sampling was conducted to monitor individuals who had the potential to breath airborne radioactivity. The second level was area monitoring inside of the containment waste structure and the waste processing structure.
This included portable air samplers that were used for general area monitoring. The third level included monitoring of air at five portable sampling stations around the site. The inspectors concluded that the licensees program for air sampling was conservative for monitoring worker exposure to potentially airborne radionuclides.
The inspectors reviewed selected results of the licensees air sampling program. The licensees staff indicated that occasional exceedances of the action level (1 derived air concentration) were being identified on a few breathing zone sample filters. The radionuclides of concern included cesium-137 and cobalt-60. In these situations, the individual was requested to undertake a whole-body count as a precaution. At the time of the inspection, no individual was assigned an internal dose based on the whole-body counting results in 2024.
Portable air samplers were being used inside containment, containment waste structure, and waste processing structure to monitor the general areas for airborne contamination.
Recent results indicated that the air contained radionuclides in very low concentrations.
No worker was assigned an internal dose in 2024 based on these sample results.
The licensee also utilized five portable effluent air samplers to monitor the airborne concentrations in outdoor areas around the site. The inspectors observed the filter changeout at one of the samplers and confirmed that the sampler was in good working order at the time of the inspection.
The inspectors reviewed selected general area air sample results that were collected during or just before the inspection. Recent sample results indicate that there were no widespread problems with ambient air concentrations that negatively impacted workers.
The inspectors conducted independent radiological assessments during site tours using a hand-held survey meter, a Radeye G gamma survey meter (Serial Number 30901, calibration due date 1/19/25). The inspectors confirmed that posted signs and survey results were consistent with regulatory requirements.
The inspectors noted good health physics controls in all areas including use of air samplers to monitor employee exposures to airborne radioactive material. Industrial samplers were observed in operation. Ventilation systems were in service to control airflow within the structures. The decommissioning work was being conducted with an emphasis on industrial and radiological safety.
c.
Decommissioning Staffing and Training The inspectors reviewed the organizational chart and confirmed that all critical positions had been filled. The licensees training program was not specifically reviewed during this inspection.
d.
Problem Identification and Resolution Section 16 of the Quality Assurance Topical Report (QATR), revision 18, requires the licensee to implement a corrective action program. The inspectors reviewed the most recent list of corrective action condition reports issued since the last inspection in this program area. No condition report of significance was identified.
1.3 Conclusions The inspectors observed decommissioning work in progress and concluded that the work was being conducted with an emphasis on industrial and radiological safety.
Critical positions in the organizational structure were staffed. The licensee continued to identify problems and implement its corrective action program in accordance with quality assurance program requirements.
Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors (IP 83801)
2.1 Inspection Scope The objectives of this portion of the inspection were to:
Verify that the site has been decontaminated to acceptable residual radioactivity levels in accordance with LTP requirements for unrestricted use.
- Verify that the licensees implementing procedures, radiological measurements, decommissioning surveys, and documentation of decommissioning surveys comply with the NRC-approved LTP.
- To conduct sufficient confirmatory or verification surveys so that NRC can verify and conclude that the licensees decommissioning activities and survey program have been implemented in a manner that provides confidence in the results that the site does not pose an undue risk to public health and safety.
2.2 Observations and Findings a.
Remediation Activities and Final Status Surveys (FSS)
As defined in NUREG-1757, volume 1, revision 2, Consolidated Decommissioning Guidance: Decommissioning Process for Materials Licensees, a FSS consists of measurements and sampling to describe the radiological conditions of a site or facility, following completion of decontamination activities (if any) and in preparation for release of the site or facility. Section 5.0 of the NRC-approved LTP provides the instructions for implementation of the site-specific FSS plan. Section 5.3 describes the FSS design requirements, and Section 5.4 provides the FSS implementation requirements. The inspectors compared the licensees design and implementation of three FSSs to the requirements provided in the LTP.
The three areas to be final surveyed included the footprints of the former chemistry and radiation protection facility, technical support center, and radwaste building. The inspectors reviewed these three FSS plans and compared the instructions provided in the packages to the requirements specified in the LTP. The inspectors noted that the three survey packages implemented the survey requirements as provided in the LTP.
These instructions included survey unit size, scan coverage, number of samples to be collected, instrumentation requirements, and surveyor requirements.
The inspectors observed the licensees implementation of the three FSS survey packages. The inspectors also attended two pre-job briefings prior to implementation of the survey packages. The inspectors confirmed that the surveyors implemented the surveys as stipulated in the survey packages. The inspectors also observed that the licensee implemented isolation and control measures, as required by Section 5.2.3.1 of the LTP, to help prevent the spread of contamination into the three survey units.
The licensees surveys included measurement of ambient gamma radiation levels and collection of soil samples. The inspectors noted that the surveyors conducted the survey as stipulated in the LTP including speed of surveyor and distance of the survey meter to the ground. The inspectors noted that the instructions in one survey unit, No. 4100, FSS of the Radwaste Building Excavation, dated October 10, 2024, did not clearly discuss the status of a manhole, buried piping, and pooled water located within the survey unit.
Licensee representatives stated that these features will be addressed prior to submittal of the final survey results for this survey unit to the NRC for review. The inspectors did not observe the collection of soil samples during the inspection.
In summary, the survey packages were developed using the instructions provided in Section 5.3 of the LTP, and the implementation of the surveys were conducted in accordance with the guidance provided in Section 5.4 of the LTP.
b.
Verification and Confirmatory Surveys The NRC contracted with Oak Ridge Associated Universities (ORAU) to develop and perform comprehensive independent confirmatory surveys such that the NRC can effectively assess the adequacy of the licensee's FSS results. During the inspection, ORAU staff conducted confirmatory surveys of embedded drain lines, outdoor areas around the facility, and within the stressing gallery. These survey results will be presented to the licensee under separate correspondence.
c.
Problem Identification and Resolution The inspectors reviewed select problems identified with FSS program, to ensure that problems being identified in the field were entered into the licensees corrective action program. The inspectors reviewed two condition reports (CR-2024-00148 and CR-2024-00171) that described the identification of elevated pockets of radioactivity in survey units that had been previously surveyed. The corrective actions included cleanup of these areas. In summary, the licensee continued to identify problems and implement corrective actions in accordance with licensee procedures.
2.3 Conclusions The licensees FSS survey program was being implemented in accordance with LTP requirements.
Radioactive Waste Treatment, and Effluent and Environmental Monitoring (IP 84750)
3.1 Inspection Scope The inspectors reviewed documents and interviewed plant personnel to assess the licensees performance in the following areas:
Radioactive waste treatment systems are maintained and operated to keep offsite doses as low as reasonably achievable.
- Licensee effectively controls, monitors, and quantifies releases of radioactive materials in liquid and gaseous, forms to the environment.
- Radiological environmental monitoring programs are effectively implemented to ensure effluent releases are being adequately performed as required to minimize public dose.
3.2 Observations and Findings a.
Changes in the Offsite Dose Calculation Manual (ODCM)
The inspectors reviewed recent changes made by the licensee to the ODCM and as well as to the liquid, gaseous, and solid radwaste system design and operation to ensure adequate evaluation and implementation within the sites licensing basis and regulations.
The inspectors conducted a review of CH-ODCM-0001, ODCM, revision 38, which included Engineering Change 70885, issued on February 8, 2022. The reason for the engineering change was to remove the auxiliary building and radwaste building ventilation effluent release path, due to the equipment no longer being in service. The inspectors reviewed the change to the ODCM and found it to be adequate and in accordance with regulatory requirements.
b.
Radioactive Gaseous and Liquid Effluent Treatment The inspectors performed a walk down of the effluent monitoring ventilation and discharge systems to verify the current system configurations, flow paths, and operations. Upon which, the inspectors conducted a review of DCSD-CH-204, Information Use Portable Effluent Air Sampling, revision 2. This procedure provided instructions for portable effluent air sampling that involves operation of portable air samplers. The procedures were found to be adequate and were being followed accordingly by the licensee. The portable effluent air samplers had adequate flow paths and were properly calibrated. The inspectors found those specific areas observed to be adequate and consistent with the description in the ODCM and site procedures.
The inspectors verified appropriate calibration of a sample of effluent monitors and for any changes to effluent monitor set points. The gaseous effluent release sample reviewed was the Supplement to Auxiliary Building Exhaust Stack Release Summary:
Special Planned Release from Waste Processing Station, Release No. 2024138. The
weekly particulate filter results demonstrated to be adequate and under regulatory limits with no significant activity.
The inspectors reviewed one radioactive gaseous and liquid waste discharge permit to verify that projected doses to members of the public were accurate, within 10 CFR Part 50, Appendix I and ODCM dose criteria. The gaseous effluent release sample reviewed was the Supplement to Auxiliary Building Exhaust Stack Release Summary:
Special Planned Release from Open Air Demolition (OAD) Effluent, Release No.
2024134; as well as the liquid effluent release sample, Special Radiological Liquid Release Permit, Release No. 2024091. The analysis of the gaseous and liquid waste discharge results demonstrated to be adequate and under regulatory limits with no significant activity.
The inspectors verified that the licensees Annual Radioactive Effluent Release Report (ARERR) was submitted as required, and that any anomalous results, unexpected trends, or abnormal releases identified were entered into the corrective action program and adequately resolved, and that the reported doses were below regulatory requirements. The inspectors reviewed the licensees ARERR for calendar year 2023 (ML24121A064). The ARERR is required by Appendix E.4.1 of the QATR. The ARERR contained the results of the effluent report as well as quarterly dose calculations performed in accordance with the ODCM for calendar year 2023. The ARERR demonstrated no abnormal releases and reported doses were below regulatory requirements. During 2023, there were as no changes to the ODCM, and the effluent monitoring program demonstrated the concept of As Low As Is Reasonably Achievable.
c.
Radiological Environmental Monitoring Program (REMP)
The inspectors conducted a review of the environmental monitoring program including field observations of equipment and procedures and review of records associated with the program. The equipment observed were properly located, calibrated, and maintained. The inspectors also conducted a review of FCSD-CH-112, Information Use OAD Sampling and Analysis, revision 1. This procedure documents the sampling and analysis of the open-air demolition stacks for alpha and particulate radioactivity. The inspectors conducted a tour of the corresponding equipment and determined that the equipment to be properly placed to adequately collect open air demolition sampling.
The inspectors reviewed the licensees annual Radiological Environmental Operating Report (REOR) for calendar year 2023. The REOR is required by the QATR Appendix E.4.2 and provides an overview of the associated REMP for calendar year 2023. The inspectors examined the REMP to determine if was compliant with the requirements established within the QATR Appendix E.3.1 and verified that the report was submitted to the NRC by the required date. Additionally, the inspectors reviewed select portions of the REMP and noted the data was within expected ranges when compared with historical results.
3.3 Conclusions In accordance with the LTP, the licensee established procedural and radiological controls for the environmental monitoring program. The inspectors reviewed the licensees environmental monitoring equipment and observed implementation of sampling procedures. Additionally, the licensee effectively implemented the liquid effluent storage and treatment system consistent with technical specifications and the ODCM.
Exit Meeting Summary The inspectors presented the final inspection results to the Regulatory Assurance &
Emergency Planning Manager, and other members of the licensees staff, at the conclusion of the onsite inspection on October 10, 2024. The inspectors asked if there were any materials examined were proprietary. No proprietary information was removed from the site.
Attachment SUPPLEMENTAL INSPECTION INFORMATION KEY POINTS OF CONTACT Licensee and Contractor Personnel B. Pearson, Regulatory Assurance & Emergency Planning Manager K. Daughenbaugh, ISFSI Shift Supervisor T. Uehling, Director Site Decommissioning R. Hugenroth, Nuclear Oversight Manager A. Hansen, Regulatory Assurance C. Heimes, Manager ISFSI Site Security A. Kodra, Project Manager FSS, EnergySolutions J. Layton, Planning & Scheduling Supervisor T. Maine, Plant Manager B. Bishop, Energy Solutions LTP/FSS Manager J. Nowak, Project Director, EnergySolutions D. Whisler, RP & Chemistry Specialist J. Hoffman, Chemistry Specialist Oak Ridge Associated Universities E. Bailey, Survey Projects Manager N. Altic, Certified Health Physicist A. Gereau, Health Physicist P. Williams, Health Physicist INSPECTION PROCEDURES USED IP 71801 Decommissioning Performance and Status Reviews at Permanently Shutdown Reactors IP 83801 Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring LIST OF ACRONYMS ADAMS Agencywide Documents Access and Management System ARERR Annual Radioactive Effluent Release Report CFR Code of Federal Regulations CR Condition Report FSS Final Status Survey IP Inspection Procedure LTP License Termination Plan NRC Nuclear Regulatory Commission OAD open air demolition ODCM Offsite Dose Calculation Manual ORAU Oak Ridge Associated Universities QATR Quality Assurance Topical Report REMP Radiological Environmental Monitoring Program REOR Radiological Environmental Operating Report