IR 05000293/2024002
| ML24227B003 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/21/2024 |
| From: | Eve E NRC Region 1 |
| To: | Trice K Holtec Decommissioning International |
| References | |
| IR 2024002 | |
| Download: ML24227B003 (1) | |
Text
August 21, 2024
SUBJECT:
HOLTEC DECOMMISSIONING INTERNATIONAL, LLC, PILGRIM NUCLEAR POWER STATION - NRC INSPECTION REPORT NO. 05000293/2024002
Dear Kelly Trice:
On June 30, 2024, 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). 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 walk-downs. The results of the inspection were discussed with John Moylan, Site Vice President, and other members of your staff on July 30, 2024, and are described in the enclosed inspection report.
Based on the results of this inspection, one 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.
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD, SUITE 102 KING OF PRUSSIA, PA 19406-1415 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 Katie Barnes of my staff at 610-337-5323 if you have any questions regarding this matter.
Sincerely, Elise Eve, Team Leader Decommissioning Team Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Radiological Safety and Security
Docket No.
05000293 License No.
Enclosure:
Inspection Report No. 05000293/2024002
w/Attachment
cc w/encl:
Distribution via ListServ
ELISE EVE Digitally signed by ELISE EVE Date: 2024.08.21 05:13:45 -04'00'
EXECUTIVE SUMMARY
Holtec Decommissioning International, LLC (HDI)
Pilgrim Nuclear Power Station (PNPS)
NRC Inspection Report No. 05000293/2024002
A routine announced decommissioning inspection was completed on June 30, 2024, at the permanently shut-down Pilgrim Nuclear Power Station (PNPS). The inspection included an assessment of the program for occupational radiation exposure; problem identification and resolution; and decommissioning performance. The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records, and plant walk-downs. The NRCs 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 20.1701 was identified for HDIs failure to control the concentration of radioactive material in air. Specifically, HDI failed to establish appropriate radiological work controls such that airborne radioactivity was generated which resulted in one individual receiving an intake of radioactive material. HDI entered the issue into its Corrective Action Program (CAP) as Issue Report (IR) PIL-07257.
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 (ADAMS Accession Number: 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 (ADAMS Accession No. ML19162A033). On August 27, 2019, an amendment was issued transferring the license from ENOI to Holtec International, LLC., (HDI)
(ADAMS Accession No. 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 (ADAMS Accession No. ML21348A748).
At the time of the inspection, PNPS was in the active decommissioning phase with no fuel in the spent fuel pool, as described in IMC 2561.
2.0 Active Decommissioning Performance and Status Review
2.1 Inspection Procedures 40801, 71801, 83750, 92702
a. Inspection Scope
The inspectors performed on-site decommissioning inspection activities on May 20 - 23, 2024 and June 26 - 27, 2024, supplemented by in-office reviews and periodic phone calls. The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records, and plant walkdowns.
The inspectors toured the main stack building to observe material condition and the status of ongoing work in that location and discussed site characterization activities. The inspectors observed work on segmentation of reactor vessel internals to determine if appropriate controls were implemented for protection of workers and the public.
The inspectors reviewed the annual reported radiation doses for licensee personnel for 2023 and dosimetry processor certification documentation to determine if radiation exposures were properly monitored and evaluated and within regulatory limits. The inspectors observed locations of controlled area dosimeters and reviewed results from the controlled area dosimeters for 2023 to determine if the dosimeters were placed appropriately and if doses were within regulatory limits for workers not provided individual monitoring. The inspectors reviewed discrepancies between the doses recorded by Dosimeters of Legal Record (DLR) and Electronic Dosimeters (ED) for 2023 and discussed with licensee personnel to determine if the site had appropriately evaluated the discrepancies and applied a technically defensible calibration bias to the EDs. The inspectors reviewed an evaluation of an error identified in lapel air sampler records resulting in an artificially high Minimum Detectable Activity (MDA) for the samples.
The inspectors discussed the status of the corrective actions for the violation relating to misuse of decommissioning trust funds identified in 2023 and began review of the overall status of the decommissioning trust fund as described in the annual Report on the Status of Decommissioning Funding for 2023.
The inspectors reviewed an incident that occurred on April 2, 2024, when a survey of the reactor vessel head generated unexpected airborne radioactive material, leading to one individual receiving an internal radiation dose. The inspectors conducted interviews and reviewed documents to determine if deficiencies existed in radiological controls and if the individuals internal exposure was appropriately evaluated. Specifically, the inspectors interviewed personnel including involved workers and supervisors to discuss the event, pre-planning, response, and site investigation. The inspectors reviewed related documents including the dose assessment, bioassay results, radiation surveys, and air sample results. The inspectors reviewed HDIs Apparent Cause Evaluation (ACE) to determine if the event was appropriately evaluated through the sites corrective action program (CAP).
b. Observations and Findings
The inspectors determined that the reactor vessel internals segmentation work observed was conducted with appropriate radiological oversight and controls.
The inspectors verified that annual radiation doses had been reported to the NRC Radiation Exposure Information and Reporting System (REIRS) as required by 10 CFR 20.2206, and that all worker doses were within regulatory and site administrative limits.
The inspectors verified that dosimeters were processed by a National Voluntary Laboratory Accreditation Program (NVLAP) accredited processor and that the approved radiation test categories were consistent with the types of radiation present. The inspectors determined that controlled area dosimeters were appropriately placed and verified that the results showed that doses to non-radiological workers were below regulatory limits. The inspectors noted that ED results for 2023 were generally lower than the corresponding DLR results, in a departure from previous trends. The discrepancies were not associated with any exceedance of dose limits. The Radiation Protection (RP) department planned to conduct additional verification of ED calibration bias during 2024.
The inspectors determined that an inaccurate MDA calculation used in lapel air sample analysis had the potential to cause low internal doses to be missed as the samples below the MDA were not further evaluated. The inspectors noted that significant doses would have exceeded the MDA for the sample and therefore would have been detected, and that gamma spectroscopic measurement of the samples provided an additional level of analysis to ensure that real doses were unlikely to have been missed. HDI performed an extent of condition review and revised the incorrect data sheets, including recalculating the erroneous results and assigning internal dose where indicated.
The inspectors verified that prompt corrective actions described in HDIs letter dated March 29, 2024, in response to the February 2024 (Notice of Violation) NOV for misuse of decommissioning trust funds, were completed and the funds used for charitable contributions were credited back to the fund with interest.
The inspectors noted that at the time of the inspection the long-term corrective actions were still in progress, and review of these actions as well as the overall status of the decommissioning trust fund will continue in the third quarter.
Violation
The NRC identified one Severity Level IV non-cited violation of 10 CFR 20.1701 for HDIs failure to control the concentration of radioactive materials in air. Specifically, HDI failed to establish appropriate radiological work controls such that airborne radioactivity was generated, which resulted in one individual receiving an internal radiation dose.
On April 2, 2024, the RP department performed a survey underneath the reactor vessel head, which currently sits on a stand on the reactor building 117 elevation. The reactor vessel head is a posted Locked High Radiation Area (LHRA), High Contamination Area (HCA), and alpha level II area. The purpose of the survey was to acquire information on radiological conditions underneath the head to determine if continuing to control it as a LHRA was necessary and to facilitate planning for segmentation and disposal of the head. A water shield structure is in place under the center of the head, reducing the available space. Information on radiological conditions underneath the head was limited prior to the survey, though the most recent survey of a small section indicated contamination levels as high as 80 mRad/hr dpm/100 cm2 and 1745 dpm/100 cm2 on the underside surface of the head.
Prior to the survey, evaluation of potential airborne levels was performed using a Common Total Effective Dose Equivalent (TEDE) As Low As Reasonable Achievable (ALARA) screening, specifying maximum allowable contamination levels according to characteristics of the planned work. The screening relied on non-conservative assumptions about the confinement of the space and potential for resuspension of contamination and considered only the contamination levels on the floor which were substantially lower than on the underside of the head. This led the RP personnel planning the work to conclude that respiratory protection was not necessary, though using the correct factors would not have supported this conclusion. No other controls such as temporary ventilation was established to mitigate the potential for airborne. The Radiation Protection Technician (RPT) performing the survey wore a double layer of protective clothing and a face shield and was instructed to maintain a crouched position to avoid contacting the more contaminated underside of the vessel head.
Upon entry under the reactor vessel head, the RPT was not able to consistently maintain the crouched position and found that the space was small enough that their outer protective clothing was brushing against the surfaces of the head. The RPT stated that they felt unable to turn around to exit and so continued with the survey. After exiting following completion of the survey, the RPT was noted to have visible dirt on their outer protective clothing and subsequently failed to clear the personnel contamination monitors. Shortly after the RPT exited the area, a nearby continuous air monitor began to alarm, indicating elevated airborne radioactivity of approximately 1.2 DAC (Derived Air Concentration). Two other RPTs remained in the work area to take confirmatory air samples and perform additional surveys and decontamination.
Confirmatory air samples in two locations showed airborne concentrations of 0.858 and 0.688 DAC.
The inspectors noted that certain aspects of the response to the airborne alarm were not consistent with site procedures or best practices. Specifically, the RPTs who remained in the area to perform additional sampling, surveys, and decontamination did so without consideration of the need to use respiratory protection. HDI entered this issue into its CAP as IR PIL-07416. In addition, procedure NISP-RP-004 states that airborne radioactivity areas are posted when concentrations of particulates and iodine are greater than or equal to 0.3 DAC, however the area was not posted.
The inspectors noted that site procedure P-EN-RP-113, RP Response to Alarms and Abnormal Radiological Conditions, did not contain specific detail on actions expected from RPTs responding to airborne alarms, such as minimizing time in the area, when to consider respiratory protection, required area postings, or specific instruction for continued air sampling.
The RPT who performed the survey was decontaminated to the extent possible and given a whole-body count, which showed internally deposited radioactive material. All other personnel who had been in the area ultimately cleared the contamination monitors after removal of low-level external contamination. Further assessment of the individuals intake of radioactive material was performed via repeated whole-body counts and in-vitro bioassays and indicated a mixture of plant-generated isotopes including transuranics. An internal dose of 132 mrem Committed Effective Dose Equivalent (CEDE) was assigned resulting from this intake, in addition to 43 mrem of external exposure from the survey activity. These doses are well below the annual limit of 5000 mrem total effective dose equivalent (TEDE) specified in the regulations in 10 CFR Part 20.
The RPT was restricted from entering the radiologically controlled area while the dose was evaluated and until the amount of radioactive material in the body had decreased to the point where it was no longer detectable by the personnel radiation monitors.
However, the RPT remained employed at the site during this time and was given alternative work assignments.
HDI promptly entered the issue into its corrective action program as IR PIL-07257 and discussed the incident with the NRC inspector via telephone on April 3, 2024. HDI conducted an Apparent Cause Evaluation (ACE) to determine the cause of the event and prescribe corrective actions. The inspectors reviewed the ACE and found that the investigation was conducted by appropriate individuals not involved in the event and that the conclusions reached relating to the inadequacy of the pre-job TEDE ALARA screening were legitimate. However, the inspectors noted that the failure to fully consider the restricted space in the pre-job planning was not identified as a causal factor, and that potential underlying factors contributing to the failure to appropriately characterize the radiological hazards associated with the survey were not evaluated.
Corrective actions identified in HDIs Apparent Cause Evaluation included training of RP personnel to reinforce expectations on stop work criteria and raising safety concerns; revising the common TEDE evaluation to better document assumptions and provide additional guidance; revising pre-job brief instructions to include review of TEDE ALARA evaluations and ALARA plans; and providing a case study to RP supervisory personnel focusing on having a full understanding of the scope and limitations of known information prior to an activity. The inspectors verified that the RP personnel training had been performed and will verify additional corrective actions when completed.
Title 10 CFR 20.1701 requires the licensee to use, to the extent practical, process or other engineering controls (e.g. containment, decontamination, or ventilation) to control the concentration of radioactive material in air.
Contrary to this requirement, HDI did not use process or engineering controls to control the concentration of radioactive material in air. Specifically, on April 2, 2024, during a survey under the reactor vessel head, HDI failed to establish appropriate radiological controls, resulting in disturbance of contamination that generated uncontrolled airborne radioactive material and led to an individual receiving an unplanned intake of radioactive material.
This violation was determined to be a Severity Level IV violation using Section 6.7 of the NRC Enforcement Policy, dated January 14, 2022, regarding violations involving Health Physics.
Because HDI placed the deficiency into its corrective action program (PIL-07257), the violation was of low safety significance, and because the violation was not willful or repetitive, this violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2.a of the NRC Enforcement Policy (NCV 05000293/2024002-01, Failure to control the concentration of radioactive materials in air).
c. Conclusions
One Severity Level IV NCV of 10 CFR 20.1701 was identified.
4.0
Exit Meeting Summary
On July 30, 2024, the inspectors presented the inspection results to John Moylan, 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
KEY POINTS OF CONTACT
- J. Moylan, Site Vice President
- J. McDonough, Decommissioning Manager
- D. Noyes, Senior Compliance Manager
- M. Lawson, Radiation Protection Manager
- A. Lombardo, RP Superintendent
- G. Madison, CHP, RP Consultant
- A. Steward, RP Supervisor
- R. Parke, Site Closure Specialist
- E. Sanchez, Radiation Protection Specialist
ITEMS OPEN, CLOSED, AND DISCUSSED
None
PARTIAL