IR 05000293/2022004
| ML23031A208 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 02/15/2023 |
| From: | Anthony Dimitriadis Decommissioning, ISFSI, and Reactor Health Physics Branch |
| To: | Trice K Holtec Decommissioning International |
| References | |
| IR 2022004 | |
| Download: ML23031A208 (1) | |
Text
February 15, 2023
SUBJECT:
HOLTEC DECOMMISSIONING INTERNATIONAL, LLC, PILGRIM NUCLEAR POWER STATION - NRC INSPECTION REPORT NO. 05000293/2022004
Dear Kelly Trice:
On December 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection under Inspection Manual Chapter 2561, Decommissioning Power Reactor Inspection Program, at the permanently shutdown Pilgrim Nuclear Power Station (PNPS).
On-site focused topical inspections were conducted on October 17 - October 21, 2022, and December 5 - December 9, 2022. Additional inspection activities (in office reviews) were conducted remotely during the inspection period. The inspection 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 walkdowns. The results of the inspection were discussed with John Moylan, Site Vice President, and other members of your staff on January 18, 2023, and are described in the enclosed report.
One NRC identified violation of NRC requirements of very low safety significance (Severity Level IV) is documented in this report. Because of the very low safety significance and because Holtec Decommissioning International, LLC (HDI) entered this issue into its corrective action program and the violation was not willful or repetitive, this violation is being treated as a Non-Cited Violation (NCV), consistent with Section 2.3.2 of the NRC Enforcement Policy.
If you contest the subject or severity of this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission - 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, 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, if any, should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. Current NRC regulations and guidance are included on the NRCs website at www.nrc.gov; select Radioactive Waste; Decommissioning of Nuclear Facilities; then Regulations, Guidance and Communications. The current Enforcement Policy is included on the NRCs Website at www.nrc.gov; select About NRC, Organizations & Functions; Office of Enforcement; Enforcement documents; then Enforcement Policy (under Related Information). You may also obtain these documents by contacting the Government Printing Office (GPO) toll-free at 1-866-512-1800. The GPO is open from 8:00 a.m. to 5:30 p.m. EST, Monday through Friday (except Federal holidays).
No reply to this letter is required. Please contact Harold (Harry) Anagnostopoulos of my staff at 610-337-5322 if you have any questions regarding this matter.
Sincerely, Digitally signed by Anthony M. Anthony M. Dimitriadis Date: 2023.02.15 Dimitriadis 09:13:23 -05'00'
Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Radiological Safety and Security Docket No. 05000293 License No. DPR-35 Enclosure: Inspection Report 05000293/2022004 w/Attachment cc w/encl: Distribution via ListServ
EXECUTIVE SUMMARY
Holtec Decommissioning International, LLC (HDI)
Pilgrim Nuclear Power Station (PNPS)
NRC Inspection Report No. 05000293/2022004 An announced routine decommissioning inspection was completed at Pilgrim Nuclear Power Station (PNPS) on December 31, 2022. On-site focused topical inspections were conducted on October 17 - October 21, 2022, and December 5 - December 9, 2022. Additional inspection activities were conducted remotely during the inspection period. The inspection included an assessment of the corrective action program (CAP), a review of routine audits, job observations of reactor internals segmentation and packaging, tours of the reactor building to assess habitability, radioactive waste management and transportation, aspects of the Title 10 of the Code of Federal Regulations (10 CFR) Part 37 material security program, and a close-out inspection of the materials control and accounting program. The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records, and plant walkdowns. The U.S Nuclear Regulatory Commissions (NRC) program for overseeing the safe decommissioning of a shutdown nuclear power reactor is described in Inspection Manual Chapter (IMC) 2561, Decommissioning Power Reactor Inspection Program.
List of Violations One Severity Level IV (SLIV) Non-Cited Violation (NCV) of 10 CFR 50.48(f)(1) was identified for HDIs failure to utilize a hot work permit to control the use of a halogen lamp in one room of the radioactive waste facility. A permit was required by procedures as a component of the required fire prevention program. Failure to control the use of the halogen lamp led to a fire. This is a Severity Level IV violation of very low safety significance. HDI entered this issue into its CAP as PIL-05631.
REPORT DETAILS
1.0 Background On June 10, 2019, Entergy Nuclear Operations, Inc. (ENOI) certified cessation of power operations and the permanent removal of fuel from the PNPS reactor vessel (Agencywide Documents Access and Management System (ADAMS) Accession No.
ML19161A033). This met the requirements of 10 CFR 50.82(a)(1)(i) and 50.82(a)(1)(ii).
On June 11, 2019, the NRC notified PNPS that the NRC would no longer perform its oversight activities in accordance with the Operating Reactor Assessment Program per IMC 0305 and that oversight would be conducted under the provisions outlined in IMC 2561 Decommissioning Power Reactor Inspection Program (ML19162A033). On August 27, 2019, an amendment was issued transferring the license from ENOI to Holtec Decommissioning International, LLC (HDI) (ML19235A050). On December 14, 2021, HDI notified the NRC of the permanent removal of all spent fuel assemblies from the spent fuel pool, with their placement in dry storage within the Independent Spent Fuel Storage Installation (ISFSI) II cask storage pad (ML21348A748).
At the time of the inspection, Pilgrim was in the active decommissioning phase with no fuel in the spent fuel pool, as described in IMC 2561.
2.0 Decommissioning Performance and Status Review 2.1 Inspection Procedure 40801, Problem Identification and Resolution
a. Inspection Scope
The inspectors assessed HDIs effectiveness at reasonably identifying and preventing problems and promptly detecting and correcting issues of concern, conditions adverse to quality, and non-conformances. The inspectors reviewed summaries of newly written issue reports (IRs) on a bi-weekly basis and, where appropriate, requested additional information.
The inspectors attended a management review committee meeting to assess site managements degree of involvement in the administration of the CAP.
The inspectors reviewed a selection of audits and assessments that were performed by HDI in order to evaluate the HDI quality assurance program. These included routine audits of the fire protection program, the ISFSI, the radiation protection program, and an audit of the implementation of the quality assurance program at Pilgrim. The inspectors reviewed the HDI Decommissioning Quality Assurance Program document and held discussions with HDI staff regarding the fleet approach to augmented quality.
The inspectors conducted focused job observations of HDI staff and HDI contractors as they performed work on the reactor building refueling floor. The inspectors assessed the safety culture and safety conscious work environment at the Pilgrim site using insights gained from the inspection. The inspectors observed that there were no HDI corporate assessments of the safety culture available for review.
The inspectors selected two apparent cause evaluations (ACE) for review and evaluation; IR PIL-04717 Non-active heat event discovered in the Old Thermex Room and IR PIL-05117 2021 radiological dose under-reported by 34%.
b. Observations and Findings
The inspectors observed that IRs were being generated at an appropriate low level of significance, and that the volume of IRs was reasonable for a site undergoing active decommissioning. The inspectors noted that site senior management was directly involved in the screening of issues, in the selection of actions, and in the review of issue resolution.
The inspectors found that the closure of corrective actions was accompanied by objective evidence of the satisfactory completion of the action.
The inspectors observed that routine quality assurance-directed audits had been completed as scheduled, and that the schedule was reasonable for a facility undergoing decommissioning.
The inspectors observed an appropriate level of HDI coordination and oversight of contractor personnel who were engaged in reactor vessel internals segmentation and packaging work on the refueling floor. The inspectors found no hesitancy to report and communicate concerns among the HDI staff and contractors.
The inspectors found that the apparent cause evaluation for IR PIL-05117 2021 radiological dose under-reported by 34% was comprehensive with appropriate corrective actions. The inspectors found that there were no Licensee Event Reports or Root Cause Analysis performed in 2022.
The inspectors determined that apparent cause evaluation for IR PIL-04717 Non-active heat event discovered in the Old Thermex Room was insufficient in that it: a) did not consider the applicability of the sites hot work procedure, b) did not review the sites program for the control of combustible material and its applicability to the event, and c) did not review the fire protection plan for the room to look for compliance and for the suitability of the existing plan for that area.
Violation During the review of this apparent cause evaluation, the NRC identified one Severity Level IV (SLIV) NCV for the fire in the Old Thermex Room of the radioactive waste facility.
Specifically, HDI failed to apply its hot work permitting process to the use of a halogen light in the room.
On May 20, 2022, a member of the Pilgrim station management team identified an acrid smell during a walkdown of the turbine building radwaste corridor. An HDI investigation revealed that a heat event had occurred in the Old Thermex Room (also called the Solidpak Room). Evidence of melted extension cords, wire housings, light housings, pump casings, and a portable ventilation unit hose was found. Charring of the wall paint and floor coatings was identified. At the time of identification, no active work was being performed in the room, and the room was not routinely accessed or occupied. HDI entered the issue into its CAP as IR PIL-04717. HDI removed the burned materials and cleaned the room.
HDI performed an Apparent Cause Analysis, Evidence of Past (Non-Active) Heat Event Discovered which was completed on June 20, 2022. HDI determined that the source of the heat event was a portable halogen work light that was left energized in the room, and which was in close proximity to combustible materials which were left in the room. Upon identification, HDI corrective actions included a walkdown of station areas to remove all halogen lamps, and a revision to the Industrial Security Patrol Checklist to ensure that vulnerable and high-risk areas were covered in routine rounds.
NRC inspectors entered the Old Thermex Room on October 19, 2022, to assess the damage to the room and equipment. The inspectors determined that a fire had taken place that resulted in a melted pump housing, completely burned a spiral-wound negative pressure ventilation hose, melted the rubber coating on several radwaste processing hoses, scorched walls, and melted the insulation of a coxial cable in proximity before it extinguished itself. At the time of the fire, the room was posted as a contamination area and a high radiation area, as well as containing radwaste processing equipment.
The inspectors reviewed HDIs Apparent Cause Analysis for the fire and determined that HDI failed to identify that the requirements provided in site procedure P-EN-DC-127, Revision 21, Control of Hot Work and Ignition Sources was applicable to the event.
Specifically, halogen lamps meet the definition of hot work in that procedure, a procedure step discusses the use of portable halogen lamps, and the procedure requires the issuance of a hot work permit for this particular application of a portable halogen lamp. The inspectors determined that HDIs failure to issue a hot work permit to control the use of a portable halogen lamp in the Old Thermex Room was the apparent cause of the fire.
HDI corrective actions, as identified in their Adverse Condition Analysis (ACA), included:
a) removing the halogen lamp and replacing it with an acceptable alternative (action 2);b) removal of all halogen lamps from plant areas (action 3); c) issuing a site-wide prohibition on the use of halogen lamps for lighting and requiring them to be continuously attended when used for other purposes (action 7); d) revision of the Industrial Security Patrol Checklist (action 4); and e) implementation of weekly management tours (action 5).
Corrective actions are documented in IR PIL-04717.
10 CFR 50.48(f)(1) requires, in part, that licensees that have submitted the certifications required under 10 CFR 50.82(a)(1) shall maintain a fire protection program to address the potential for fires that could cause the release or spread of radioactive materials, including reasonably preventing these fires from occurring.
Procedure P-EN-DC-127, Control of Hot Work and Ignition Sources, Revision 21, Step 5.2[1], states that all hot work activities shall be authorized through the issuance of an approved hot work permit (Attachment 9.1) except as listed in Steps 5.2[6], 5.2[7] and 5.2[8] of the procedure. Step 5.2[7], states in part, that hot work permits, and fire watches are not required in the area or conditions listed below, which include
- (f) portable quartz halogen lamps provided they are firmly anchored or attached in such a manner to prevent the lamp from falling. No combustibles materials shall be stored within five feet of the lamp.
Contrary to the above, on May 20, 2022, HDI failed to issue an approved hot work permit for the use of a portable halogen lamp in the Old Thermex Room. The halogen lamp was not anchored or attached in such a manner to prevent the lamp from falling, and HDI allowed combustible materials to be stored within 5 feet of the halogen work lamp, which was left energized and subsequently resulted in a fire. This failure was within HDIs ability to foresee and prevent.
Consistent with the guidance in Section 2.6.D of the NRC Enforcement Manual, if a violation does not fit an example in the Enforcement Policy Violation Examples, it should be assigned a severity level
- (1) commensurate with its safety significance and
- (2) informed by similar violations addressed in the Violation Examples. The issue of HDIs use of a portable halogen lamp in the Old Thermex Room was not found to match any of the Violation Examples; however, the issue was determined to be a SLIV NCV. This determination was made because the consequences of the fire were limited to an area within one room, there was no breach of a radioactive system, no spread of radioactivity as a result of the fire, and no potential for a spread of radioactive material to the public or the environment.
Because HDI entered this issue into the Pilgrim CAP (PIL-05631) and the violation was not willful or repetitive, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000295/2022004-001)
c. Conclusions
One SLIV NCV of 10 CFR 50.48(f)(1) and procedure P-EN-DC-127, Control of Hot Work and Ignition Sources, Revision 21, was identified.
2.2 Inspection Procedure 83750, Occupational Radiation Exposure at Permanently Shutdown Reactors
a. Inspection Scope
The inspectors attended routine pre-job briefings between HDI supervision and contract work personnel who were working to segment reactor internal components and package the cut materials in the reactor cavity, dryer/separator pit, and (former) spent fuel pool. The inspectors directly observed work on the reactor building refueling floor and interviewed personnel in their work environment.
The inspectors performed walkdowns of the reactor building, including all lower-level quadrant (quad) rooms to assess the radiological, industrial safety, and environmental conditions.
b. Observations and Findings
The inspectors observed effective routine communication between HDI radiation protection staff and the contract workers who were conducting reactor segmentation and packaging work on the reactor building refueling floor. The inspectors observed adequate oversight of the contractors by HDI project management staff.
The inspectors reviewed radiological surveys and air samples as part of a pre-job briefing for entry into the spent resin tank room and its anteroom (map #125) as part of Inspection Procedure 86705 (described later in this report). The inspectors identified several concerns with radiological air sample collection and analysis, including: a) inadequate air volume (which affected the ability to assess the potential alpha emitting radionuclide component);b) a lack of evaluation of the beta emitting radionuclide component following routine radiological decay of the sample; c) the physical placement of the air sampler in the working environment, and d) approval of the air sample report with an inadequate minimum detectable concentration for the alpha emitting radionuclides. HDI wrote IR PIL-05314 to capture, evaluate and resolve these concerns.
c. Conclusions
No violations of NRC requirements were identified.
2.3 Inspection Procedure 86705, Solid Radioactive Waste Management and Transportation of Radioactive Materials
a. Inspection Scope
The inspectors walked down all available radioactive waste storage areas and radioactive source storage areas to determine if radioactive materials are controlled, labelled, posted, and secured against unauthorized removal; and that storage areas meet the requirements of the site licensing basis. The inspectors observed the material condition of a selection of radioactive waste storage containers and verified that HDI is performing periodic container inventories and inspections.
The inspectors verified that routine sealed radioactive source inventories and leak tests had been performed, and that transactions involving nationally-tracked sources were reported in accordance with 10 CFR 20.2207. The inspectors entered the spent resin tank room (and its anteroom), the chemical waste pump and tank rooms, and the New Thermex room in the Pilgrim radiological waste facility to observe the radiological and material conditions of the facilities. The inspectors walked down the accessible portions of radiological waste processing systems in the Old Thermex and New Thermex rooms of the radiological waste facility.
The inspectors reviewed a selection of shipping packages to determine if they had been appropriately characterized, classified, and prepared in accordance with the Pilgrim procedures. The inspectors discussed the radiological characterization of 145 control rod drive inner filters (for shipment) with HDI and supporting contractor staff. The inspectors also examined aspects of the 10 CFR Part 37 security plan, including a tour of the industrial security area boundaries, a walkdown of storage areas for category 1 and category 2 materials, a review of the security plan document with HDI management, and a review of IRs.
b. Observations and Findings
The inspectors found that the radiological and material conditions of the rooms and processing systems in the radioactive waste facility (that were examined during the inspection) were reasonable for the age of the facility and its decommissioning status. The inspectors noted good use of the corrective action process by the HDI shipping staff and its contractor. The inspectors developed several concerns with the implementation of the 10 CFR Part 37 security program at the Pilgrim site that will be inspected during a future inspection in 2023. The results of that inspection will be provided in a separate report.
c. Conclusions
No violations of NRC requirements were identified.
2.4 Inspection Procedure 85103, Material Control and Accounting at Decommissioning Nuclear Power Reactors
a. Inspection Scope
The inspectors reviewed HDIs programs and procedures that are approved by management, and which cover all aspects of material control and accounting.
The inspectors evaluated the sites receipt, movement, physical inventory, shipment and reconstitution of both fuel and non-fuel special nuclear material (SNM) and assessed if they were documented. The inspectors reviewed a representative sample of 10 SNM transfer forms.
The inspectors reviewed all CAP documents related to the material control and accounting program for the last 12 months.
b. Observations and Findings
The inspectors verified that physical inventories of SNM were conducted every 12 months and examined the content of the most recent inventory report. The inspectors noted that all fuel and non-fuel SNM has either been placed in the ISFSI on-site or has been shipped from the site for disposal. Future material control and accounting activities will consist of a routine annual inventory of the welded containers that are stored in the Pilgrim ISFSI facility.
c. Conclusions
No violations of NRC requirements were identified.
3.0
Exit Meeting Summary
On January 18, 2023, the inspectors presented the inspection results to John Moylan, Pilgrim Site Vice President, and other members of the HDI staff. No proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
J. Moylan - Site Vice President
J. McDonough - Decommissioning Manager
D. Noyes - Senior Compliance Manager
M. Lawson - Radiation Protection Manager
M. Thornhill - Certified Health Physicist
A. Steward - RP Supervisor
J. Piquete - Security Supervisor
B. McWilliams - Security Manager
J. Buckley - Waste Management Lead
J. Voegtli - Waste Shipper (Waste Control Specialists)
N. Coderre - RP Supervisor
D. Burke - QA Manager
P. Kristian - Special Nuclear Materials Manager
E. Posivak - Waste Control Specialists
ITEMS OPEN, CLOSED, AND DISCUSSED
None
LIST OF DOCUMENTS REVIEWED
Adverse Condition Evaluation (ACE), 2021 Personnel Dose Underreported, IR PIL-05117,
Revision 0
Adverse Condition Analysis (ACA), Evidence of Past (Non-Active) Heat Event Discovered,
IR PIL-04717, Revision 0
Audit 2022-I-09, Internal Audit Report - Independent Spent Fuel Storage Installation-Only
(ISFSI-O) Quality Assurance Program, dated 11/4/2022
Audit 2021-I-22, Internal Audit Report - Fire Protection, dated 1/24/2022
Audit 2021-I-25, Internal Audit Report - Independent Spent Fuel Storage Installation, dated
1/3/2022
Audit 2021-I-27, Internal Audit Report - Radiation Protection Program, dated 5/26/2022
CD-20, Decommissioning Quality Assurance Program (DQAP), Revision 1
Check-sheet, Industrial Security rounds, IS-NSF-27, Revision 28
Check-sheet, Weekly Accountability of 10CFR37 Category 1 and 2 Material, IS-NSF-122,
Revision 1
Disposition Survey Plan #2022-05 Addendum, PNPS Trash Compactor Facility (TCF), dated
10/6/2022
Document, Security Diesel Protocols During Inclement Weather, NSF-342-12, Revision 0
DSP-RA-001, Corrective Action Program, Revision 0
Engineering Report 89XM-1-ER-Q, Updated Fire Hazards Analysis, Revision 21
ENN-MS-S-009-PNP, Pilgrim Safety Classification Site Specific Guidance and System Safety
Function Sheets, Revision 7
Investigation report for shipment 22-104, dated 3/20/2022
Issue Reports PIL-02672, 02971, 03005, 03199, 03618, 04234, 04302, 04379, 04390,
04592, 04911, 05047, 05117, 05147, 05175, 05176, 05205, 05206, 05207, 05260, 05208,
05360, 05488
Issue Report screening package for Management Review Committee (MRC) for meeting on
10/19/2022
Item Control Area Transfer Forms (MC&A) 2022-01, 2022-005, 2022-006, 2022-008, 2021-114,21-113, 2021-106, 2021-94, 2021-90, 2021-84
Log, 2022 PNPS Waste Tracking
NPS Waste Focus (report) dated 12/01/2022
P-EN-DC-127, Control of Hot Work and Ignition Sources, Revision 21
P-EN-DC-161, Control of Combustibles, Revision 21
P-EN-DC-330, Fire Protection Program, Revision 8
P-EN-NF-200, Special Nuclear Material Control, Revision 16
PNPS 6.1-222, REE# 11-007, Addendum 41, 10CFR61 Waste Stream Sampling Frequencies,
dated 4/25/2022
PNP-NSF-27, Industrial Security Patrol Checklist with Fire Surveillance, Revision 12
Procedure 5.5.2, Special Fire Procedure, Revision 62
Procedure 6.3-061, Special Radiological Survey Techniques, Revision 33
Radiological air samples 2022-0218, 0223, 0224
Radiological Engineering Evaluation 19-039 Addendum 22, Free-Release Survey Plan for
Upper-Security Building (SAP), Revision 00
Radiological Engineering Evaluation 19-039 Addendum 23, Release for Unrestricted Use
Survey Plan for Security Diesel Generator Building, Revision 01
Radiological Engineering Evaluation 19-039 Addendum 25, Release for Unrestricted Use
Survey Plan for Station Blackout (SBO) Diesel Generator Building, Revision 01
Radiological Engineering Evaluation 19-039 Addendum 26, Free-Release Survey Plan for
Safety Enhancement Program (SEP) Building, Revision 00
Radiological surveys 2022-0013, 0404, 0775, 1028, 1044, 1065, 1111, 1118, 1204
Radiological survey map #111 dated 9/19/2022
Report, 2022 Pilgrim Station Special Nuclear Material Physical Inventory Report, work order
WO-50080082-01-02, report date 10/25/2022
Shipping packages for shipments21-111, 21-142,22-101, 22-102,22-104 (CRD inner filters,
Cat 2 material),22-114
Work order 50080082-01-03, EN-NF-200 SNM Inventory & Transfer Control (Physical
Inventory) dated 10/26/2022
LIST OF ACRONYMS USED
ACA Adverse Condition Analysis
ACE Apparent Cause Evaluation
ADAMS Agencywide Documents Access and Management System
CAP Corrective Action Program
CFR Code of Federal Regulations
CRD Control Rod Drive
ENOI Entergy Nuclear Operations, Inc
GPO Government Printing Office
HDI Holtec Decommissioning International, LLC
IMC Inspection Manual Chapter
IR Issue Report
ISFSI Independent Spent Fuel Storage Installation
MC&A Material Control and Accounting
MRC Management Review Committee
NCV Non-Cited Violation
NRC U.S. Nuclear Regulatory Commission
PNPS Pilgrim Nuclear Power Station
RP Radiation Protection
SEP Safety Enhancement Program
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