IR 05000285/2025002
| ML25127A023 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 05/12/2025 |
| From: | Jeffrey Josey NRC/RGN-IV/DRSS/DIOR |
| To: | Via T Omaha Public Power District |
| References | |
| IR 2025002 | |
| Download: ML25127A023 (1) | |
Text
May 12, 2025
SUBJECT:
FORT CALHOUN STATION - NRC INSPECTION REPORT 05000285/2025-002
Dear Troy Via:
This letter refers to the U.S. Nuclear Regulatory Commission (NRC) decommissioning inspection conducted on April 14-16, 2025, 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 inspection on April 16, 2025. 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, problem identification and resolution program, and final status surveys conducted at the site. 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 050-00285/2025-002 Electronic Distribution via LISTSERV Signed by Josey, Jeffrey on 05/12/25
ML25127A023 SUNSI Review By: CRD ADAMS:
Yes No Sensitive Non-Sensitive Non-Publicly Available Publicly Available Keyword:
NRC-002 OFFICE SHP:DRSS/DIOR HP:DRSS/DIOR SHP:DRSS/DIOR BC:DRSS/DIOR NAME REvans CDennes SAnderson JJosey SIGNATURE
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DATE 05/08/25 05/09/25 05/08/25 05/12/25
Enclosure U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.
050-00285 License No.
DPR-40 Report No.
050-00285/2025-002 Licensee:
Omaha Public Power District Facility:
Fort Calhoun Station Location:
9610 Power Lane Blair, Nebraska Inspection Dates:
April 14-16, 2025 Inspectors:
Christian R. Dennes, Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Robert J. Evans, PhD, PE, CHP, Senior Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Accompanied By:
Muhammadali Abbaszadeh, Senior Health Physicst 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 050-00285/2025-002 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 Reviews at Permanently Shutdown Reactors
The licensee effectively implemented its decommissioning activities in accordance with the approved procedures and commitments provided in the License Termination Plan. The licensee maintained adequate radiological control over these work activities. The inspectors reviewed the previously cited violation and concluded that the licensees actions to be adequate and closed the cited violation. (Section 1.2)
Problem Identification and Resolution at Permanently Shutdown Reactors
The licensee implemented its corrective action, quality assurance audit, and safety culture monitoring programs in accordance with the Quality Assurance Topical Report and procedural requirements. (Section 2.2)
Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors
The licensee implemented its radiological survey program in accordance with approved procedures and regulatory requirements. The licensee continued to identify, document, and resolve problems in the remedial action support surveys program area. (Section 3.2)
Report Details Summary of Site Status Fort Calhoun Station permanently ceased power operations in 2016. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.82(a)(9), an application for license termination must be accompanied or preceded by the license termination plan (LTP). Revision 1 of the LTP was dated December 6, 2023 (ML23346A152). The NRC approved Revision 1 by license amendment dated January 31, 2024 (ML24019A167).
Since the previous inspection, the licensee completed the demolition of the mausoleum. During the onsite inspection, the licensee continued to conduct radiological assessments of the interior of containment and the auxiliary basement.
Decommissioning Performance and Status Reviews at Permanently Shutdown Reactors (IP 71801)
The inspectors observed site activities, reviewed documents, 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 attended a daily site status meeting to ensure that the licensee and its decommissioning contractor continued to plan and implement decommissioning in a controlled manner. The inspectors conducted site tours, in part, to observe decommissioning activities in progress. The inspectors observed the In Situ Object Counting System (ISOCS) and the removal of concrete samples inside of the empty containment structure with the ventilation system in service. The inspectors conducted a tour of the Waste Processing Structure to evaluate whether required maintenance is being performed, and housekeeping was maintained. The inspectors observed the area where the mausoleum structure was previously occupied and noted that no structural material remains from the demolition. The inspectors noted good industrial safety controls and housekeeping in all locations observed.
The inspectors conducted independent radiological surveys during site tours using a Thermo Scientific Radeye PRD survey meter (serial number 31893, calibration due date of 7/23/2025). Overall, the measured exposure rates were consistent with existing signs, boundaries, and postings.
b.
Decommissioning Operations The inspectors performed a plant tour to assess field conditions and decommissioning activities by assessing material condition of structures, housekeeping, and worker level of knowledge of procedure use. The inspectors attended a pre-job briefing for the Final Status Survey (FSS) decommissioning activities, to understand the work in progress at the site. The inspectors noted that the FSS pre-job briefing provided adequate information about the field conditions, decommissioning activities, and overall safety for the staff onsite and offsite. The inspectors observed FSS group conducting ISOCS surveys below ground level inside of containment. The inspectors also observe the removal of core concrete samples from the containment building. The inspectors interviewed staff in those corresponding areas and found the selected staff to be knowledgeable in executing their procedures.
c.
Decommissioning Staffing and Training The inspectors reviewed the organizational chart and confirmed that all critical positions had been filled.
d.
Notice of Violation 05000285/2024-004-01 (Closed) Radioactive Material Shipment Package Dose Rate Exceeded (49 CFR 173.441)
During the December 2024 inspection (ML25027A457), the inspectors identified an Apparent Violation involving the licensees failure to design and prepare radioactive materials for shipment so that, under conditions normally incident to transportation, the radiation level does not exceed 200 millirem per hour at any point on the external surface of the package as required by 49 CFR 173.441, a violation of 10 CFR 71.5 requirements. Specifically, the licensee shipped a package containing radioactive materials such that when the package arrived at its destination on November 14, 2024, radiation levels of approximately 765 millirem per hour were measured on the side of the railcar, exceeding the regulatory limit of 200 millirem per hour.
The licensee responded to the violation by letter dated February 26, 2025 (ML25063A277). This letter included the corrective actions completed by the licensee.
The NRC acknowledged the licensees response by letter dated March 18, 2025 (ML25076A670). After completion of the enforcement process, the NRC issued the formal Notice of Violation by letter dated April 16, 2025 (ML25099A323).
The inspectors reviewed the licensees corrective actions and concluded that the licensees actions should reasonably prevent a recurrence of the incident.
1.3 Conclusions The licensee effectively implemented its decommissioning activities in accordance with the approved procedures and commitments provided in the LTP. The licensee maintained adequate radiological control over these work activities. The inspectors reviewed the previously cited violation and concluded that the licensees actions to be adequate and closed the cited violation.
2 Problem Identification and Resolution at Permanently Shutdown Reactors (IP 40801)
2.1 Inspection Scope The inspectors reviewed the licensees implementation of selected portions of the quality assurance program to:
Evaluate the effectiveness of the licensees controls in identifying, resolving, and correcting issues in accordance with the NRC-approved quality assurance (QA)
program.
- Determine whether audits and assessments were conducted in accordance with the requirements provided in the NRC-approved QA program.
Confirm that the licensee had established, implemented, and performed management oversight for the safety conscious work environment.
2.2 Observations and Findings a.
Corrective Action Program (CAP)
Section 16 of the Quality Assurance Topical Report (QATR), NO-FC-10, revision 17, provided the high-level CAP requirements. Details of the program requirements were provided in procedure FCSI-RA-301, Decommissioning Corrective Action Program, revision 4. The inspectors reviewed the applicable procedure and interviewed the CAP program manager. The topics discussed included trends, challenges, staffing, and management support for the program. The licensee issued monthly CAP trend reports, and the inspectors reviewed the most recent trend report.
The inspectors review included how the licensees staff screened and reviewed incoming concerns into the CAP program. These incoming concerns were initially screened, in part, to determine if sufficient information was provided, or if additional information was needed. The licensees management review committee then conducted a high-level review of the condition reports. The condition reports were assigned for a follow up review and tracked to completion. Some of the higher-level concerns may include a root cause analysis. In summary, the licensee was found to be implementing its CAP program in accordance with QATR and procedural requirements.
b.
Quality Assurance Audit Program Section 18 of the QATR requires the licensee to establish and implement measures of planned and documented audits to verify compliance with all aspects of QATR.
Procedure FCSI-NO-200, Quality Assessments, revision 9, provided details for scheduling, preparation, performance, reporting, and follow up of audits, assessments, and surveillances. The inspectors reviewed the most recent audit schedule, audit reports, vendor reviews, and external reviews. The inspectors also interviewed the individual who was responsible for implementing the audit program.
The most recent audit, Audit NOSA-FCS-24-01, dated September 3, 2024, was a combined audit of various program areas. The audit was found to be comprehensive.
The audit report included several deficiencies and program enhancements. Condition reports were issued to track the status of each of the identified items. Additional audits and annual supplier evaluations were conducted for selected vendors. The inspectors confirmed that key auditors continued to be trained and qualified to conduct audits.
In accordance with Appendix D to the QATR, the licensee occasionally requested independent management assessments, to assess the effectiveness of the quality assurance program. The last assessment was conducted in 2023. In summary, the licensee implemented its QA audit program in accordance with QATR and procedural requirements.
c.
Safety Conscious Work Environment Regulatory Issues Summary 2005-18, Guidance for Establishing and Maintaining a Safety Conscious Work Environment, dated August 25, 2005, explains the concept of safety culture. Safety culture is described as, the necessary full attention to safety matters. A strong safety culture is also often described as having a safety-first focus.
Attributes include the safety-over-production principle, procedural adherence, and conservative decision-making. The inspectors reviewed the licensees program requirements and interviewed responsible staff to determine if the licensee continued to monitor its safety culture.
The licensee used procedure FCSI-RA-307, Safety Culture Monitoring, revision 1, to help monitor the health of the nuclear safety culture. The licensee established a safety culture monitoring panel to provide oversight of the site safety culture. The licensees oversight includes a review of safety culture inputs every six months and performance of an annual assessment. The licensee did not maintain an onsite employee concerns program but maintained a similar corporate level program. Based on the licensees 2024 review, the available data did not support the conclusion that an adverse nuclear safety culture environment existed. In summary, the licensee continued to monitor the onsite safety culture in accordance with a site procedure.
2.3 Conclusions The licensee implemented its corrective action, quality assurance audit, and safety culture monitoring programs in accordance with the QATR and procedural requirements.
Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors (IP 83801)
3.1 Inspection Scope The inspectors observed site activities, reviewed documents, and interviewed site personnel to verify that the permanently shutdown power reactor site has been decontaminated to acceptable residual radioactivity levels and to verify that the licensees procedures, radiological measurements, decommissioning surveys, and documentation of decommissioning surveys were implemented in accordance with NRC guidance.
3.2 Observations and Findings a.
Remediation Activities and Final Status Surveys On January 20, 2025, Oak Ridge Institute for Science and Education (ORISE) submitted a report (ML25030A329) discussing the confirmatory survey and Radiological and Environmental Sciences Laboratory (RESL) sample analyses conducted for Survey Units 8101, 8104, 8105, 8106, 8109, 8110, and 8307. This survey was conducted in support of the Fort Calhoun Station Phase 1 FSSR (ML24114A232) evaluation. The ORISE team performed independent visual inspections, gamma surface scans, and judgmental sampling at locations exhibiting slightly elevated levels above background during the dates June 25 and August 6-8, 2024. ORISE concluded that all soil sample Radionuclides of Concern (ROC) concentrations were less than the respective Operational Derived Concentration Guideline Levels (DCGLs) with all samples having a sum of fractions of less than unity. ORISE did not identify any anomalies that preclude soil data from demonstrating compliance with release criteria, and the confirmatory survey data supports the Fort Calhoun Station survey unit classifications. NRC staff reviewed the survey methods and sample analyses for the survey units and agree with the ORISE conclusions.
The Fort Calhoun Station approved LTP indicates that appropriate radiological and environmental programs will be maintained throughout the decommissioning process to ensure radiological safety of the workforce and the public, and environmental compliance is maintained. The inspectors reviewed selected areas of the licensees Remedial Action Support Surveys (RASS) and FSS to ensure that surveys were conducted in accordance with procedural requirements. Specifically, the inspectors reviewed the licensees implementation of its Radiological Survey Program. The methods used at the site to evaluate the extend of the radiation, contamination, and airborne radioactivity levels present at the site are described in procedure FCSD-RP-300, Radiological Survey Program, revision 4. The Radiological Survey Program is used to limit the potential for cross-contamination from other decommissioning activities and to indicate the methods used for performing surveys at the site to maintain compliance. These methods are used in areas within the radiological contaminated area that must be surveyed periodically, and that the frequency should be based upon the potential for changing radiological conditions and as low as is reasonably achievable considerations. These methods of measurements include indirect, direct and discrete radioactive particle survey method. At the time of the inspection, the licensee established and implemented a program consistent with procedure requirements and regulatory requirements.
The inspectors while conducting site tours, observed surveys being taken, and the radiological instruments used to analyze those surveys and in support of FSS and RASS work activities. The inspectors observed the radiological instruments to verify that instruments are well maintained, calibrated and were adequate to detect the ROC and DCGLs. The specific radiological instruments the inspectors reviewed on the field demonstrated to be adequate and calibrated to detect the ROC and DCGLs.
b.
Verification and Confirmatory Surveys The inspectors collected split core samples with the licensee, to conduct a confirmatory survey to verify the licensees core sample analysis is in accordance with procedures and regulatory requirements. The inspectors gather a total of ten samples from seven different survey units where core concrete samples were taken from. RESL is analyzing the samples for hard to detect and the ROC for those corresponding survey units.
3.3 Conclusions The licensee implemented its radiological survey program in accordance with approved procedures and regulatory requirements. The licensee continued to identify, document, and resolve problems in the remedial action support surveys program area.
Exit Meeting Summary The inspectors presented the preliminary inspection results to the licensees management and other members of the licensees staff at the conclusion of the inspection exit meeting on April 16, 2025. The inspectors asked if 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 ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed 05000285/2024-004-01 NOV Radioactive Material Shipment Package Dose Rate Exceeded (49 CFR 173.441)
Discussed None PARTIAL LIST OF DOCUMENTS REVIEWED Procedures NO-FC-10, Quality Assurance Topical Report, revision 17 FCSI-NO-200, Quality Assessments, revision 9 FCSD-RP-300, Radiological Survey Program. revision 4 FCSD-RP-301, Discrete Radioactive Particle Control, revision 4 FCSD-RA-LT-302, " Final Status Survey Sample Plan Development, revision 2 FCSD-RA-LT-302-F-03, FSS Instructions, revision 0 FCSD-RA-LT-303-F-01, Area Turnover and Control Checklist, revision 0 FCSD-RA-LT-304, Final Status Survey Data Assessment, revision 1 FCSD-RA-LT-305, Final Status Survey Data Reporting, revision 0 FCSD-RA-LT-306, Radiological Assessments and Remedial Action Support Surveys, revision
Licensing Bases Documents Fort Calhoun 1 Technical Specification, Amendment 299 License Termination Plan, January 31, 2024 Miscellaneous
FCS Radiological Surveys Completed Since October 10, 2024.
FCS Building Structure Layout 1 FCS Building Structure Layout 2 FCS Survey Unit Status 03112025 Layout Procedures/Forms Fort Calhoun Station Radiation Protection Form, Survey M-20250414-7 Fort Calhoun Station Radiation Protection Form, Survey M-20250415-2 INSPECTION PROCEDURES USED IP 71801 Decommissioning Performance and Status Reviews at Permanently Shutdown Reactors IP 40801 Problem Identification and Resolution at Permanently Shutdown Reactors IP 83801 Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors LIST OF ACRONYMS ADAMS Agencywide Documents Access and Management System CAP Corrective Action Program CFR Code of Federal Regulations DCGLs Derived Concentration Guideline Levels FCS Fort Calhoun Station FSS Final Status Survey ISOCS In Situ Object Counting System IP Inspection Procedure LTP License Termination Plan NRC Nuclear Regulatory Commission ORISE Oak Ridge Institute for Science and Education QATR Quality Assurance Topical Report RASS Remedial Action Support Surveys RESL Radiological and Environmental Sciences Laboratory ROC Radionuclides of Concern