IR 05000293/2024003
| ML24323A178 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 11/20/2024 |
| From: | Eve E NRC Region 1 |
| To: | Trice K Holtec Decommissioning International |
| References | |
| IR 2024003 | |
| Download: ML24323A178 (1) | |
Text
November 20, 2024
SUBJECT:
HOLTEC DECOMMISSIONING INTERNATIONAL, LLC, PILGRIM NUCLEAR POWER STATION - NRC INSPECTION REPORT NO. 05000293/2024003
Dear Kelly Trice:
On September 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 October 24, 2024, and are described in the enclosed inspection report.
Within the scope of this inspection, no violations of more than minor safety significance were identified.
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 NRC's 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 NRC's 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).
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD, SUITE 102 KING OF PRUSSIA, PA 19406-1415 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. 05000293/2024003
w/Attachment
cc w/encl:
Distribution via ListServ
ELISE EVE Digitally signed by ELISE EVE Date: 2024.11.20 14:31:19 -05'00'
EXECUTIVE SUMMARY
Holtec Decommissioning International, LLC (HDI)
Pilgrim Nuclear Power Station (PNPS)
NRC Inspection Report No. 05000293/2024003
A routine announced decommissioning inspection was completed on September 30, 2024, at the permanently shut-down Pilgrim Nuclear Power Station (PNPS). The inspection included an assessment of the programs for occupational radiation exposure; decommissioning performance; radioactive solid waste management; radioactive material storage and control; radioactive waste treatment; and effluent and environmental monitoring. 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.
Based on the results of this inspection, no violations of more than minor safety significance were identified.
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, 84750, 86750
a. Inspection Scope
The inspectors performed on-site decommissioning inspection activities on July 29 - 31 and September 9 - 12, 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 performed walkdowns of security zones where category 1 or category 2 quantities of radioactive material are stored, to assess whether HDI maintained the capability to continuously monitor and detect unauthorized entries into the security zones and to detect unauthorized removal of material as required by 10 CFR Part 37, Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material. The inspectors visited security monitoring locations, discussed alarm response procedures with security personnel, and observed a test of an intrusion detection system to evaluate HDIs ability to assess and respond to unauthorized access to security zones. The inspectors interviewed personnel and reviewed documentation to determine the adequacy of HDIs access authorization program and whether employees are given training on the site Part 37 security plan commensurate with their duties. Additionally, the inspectors reviewed the PNPS Part 37 security plan to determine whether it adequately established the overall security strategy to ensure the effective functioning of the security program.
The inspectors conducted walkdowns of radioactive waste and sealed source storage areas to assess the effectiveness of the licensees program for handling and storage of radioactive material. The inspectors reviewed documentation of sealed source leak tests and inventories and discussed the sealed source control program with the source custodian to determine if sealed sources were appropriately accounted for.
The inspectors attended several routine radiation protection (RP) plan-of-day meetings and pre-job briefings, and observed ongoing work cleaning up debris from the reactor cavity and conditions on the refuel floor, including housekeeping and radiological controls. The inspectors also observed the removal of a charcoal adsorber vessel from the augmented off-gas (AOG) building to determine whether the work was adequately planned and controlled to ensure worker safety and minimize the potential for spread of contamination.
The inspectors reviewed activities and documentation associated with radioactive effluent control and the radiological environmental monitoring program (REMP) to assess whether discharges of radioactive materials are adequately quantified and evaluated from all release points, releases from unmonitored and uncontrolled pathways are precluded, and that the REMP effectively quantifies the impact of radioactive effluent releases to the environment and sufficiently validates the integrity of the radioactive gaseous and liquid release program. The inspectors reviewed the Offsite Dose Calculation Manual (ODCM), Annual Radiological Effluent Release Report (ARERR),and Annual Radiological Environmental Operating Report (AREOR); conducted walkdowns of portions of the liquid waste processing systems, including the clean waste and chem waste tanks and spent fuel pool cooling and cleanup system; conducted walkdowns of portions of the ventilation system discharging through the reactor building vent (RBV); observed collection of weekly tritium and particulate samples from the RBV and analysis of a particulate sample; observed collection of surface water samples from the discharge canal and environmental air samples from selected monitoring stations; and observed the location and condition of selected environmental thermoluminescent dosimeters (TLDs). The inspectors reviewed the sites methodology for calculating gaseous releases from the RBV and resulting doses to the public and discussed the sites groundwater monitoring program.
The inspectors reviewed the HDI annual report on status of decommissioning funding, as well as additional information provided in response to questions by the inspectors regarding increases in remaining costs, to evaluate the overall status of the decommissioning trust fund. The inspectors discussed the questions in section 03.04 of inspection procedure 71801 with HDI personnel to determine if any triggers were met for a spot check by the NRC Financial Assessment Branch. The inspectors reviewed the status of corrective actions taken in response to a cited violation of 10 CFR 50.82(a)(8),issued on February 29, 2024, for misuse of decommissioning trust funds.
During an inspection conducted between January 1, 2024, and March 30, 2024, the NRC identified a violation of 10 CFR 50.7(f) at HDIs Indian Point Energy Center (IPEC)facility for restrictive language used in HDI employee agreements which was documented in a Notice of Violation. The inspectors reviewed the affected HDI employee agreements in use at PNPS and associated documentation to determine whether corrective actions described by HDI in its response to the violation had been adequately implemented and whether extent of condition at PNPS had been evaluated.
b. Observations and Findings
The inspectors verified that category 1 and category 2 radioactive materials were stored within established security zones, that PNPS established and maintained the capability to monitor, detect, assess, and respond to unauthorized access to the materials, and that access to the security zones was controlled in accordance with regulatory requirements. The inspectors verified that the PNPS Part 37 security plan and associated procedures contained site-specific information describing how the requirements of the security program are met, that annual security program reviews had been conducted, and that personnel were trained commensurate with their duties.
The inspectors observed that containers of stored radioactive waste were in adequate material condition, properly labeled, and secured from unauthorized removal, and verified that the site performed periodic surveillances of the stored waste. The inspectors determined that sealed radioactive sources were properly secured, and that inventories and leak testing of the sources was performed in accordance with site procedures. The inspectors noted that corrective actions were established to improve the sealed source control program following the identification of several missing sources reported to the NRC in October 2023.
The inspectors observed adequate radiological controls during the removal of a charcoal adsorber vessel from the AOG building and during work on the refuel floor. During walkdowns, the inspectors noted poor housekeeping conditions on the refuel floor and PNPS staff took prompt action to improve conditions following this observation.
The inspectors determined that effluent releases to the environment had been properly controlled, monitored, and quantified in accordance with NRC requirements. There were no liquid effluent releases reported in 2023 or to date in 2024. The inspectors noted that the 2023 AREOR and ARERR demonstrated that calculated doses were below the regulatory limits. The inspectors determined that environmental air and water samples and reactor building vent tritium and particulate samples were collected in accordance with the ODCM and site procedures and that the placement and condition of environmental air samplers and dosimeters was adequate. The inspectors noted that the observed portions of the liquid waste processing, gaseous effluent, and spent fuel pool cooling and cleanup systems were in adequate material condition with no evidence of leakage.
The inspectors determined that the overall status of the decommissioning trust fund was adequate to support the remaining decommissioning, spent fuel storage, and site restoration costs and that no criteria were met to trigger further NRC review. The inspectors noted that the independent extent of condition review of decommissioning trust fund expenditures identified as a corrective action in HDIs response to the February 29, 2024, Notice of Violation had yet to be completed at the end of the inspection period. The NRC will complete review of the corrective actions when all items have been completed. An open item was initiated to track the NRCs continued review of corrective actions implemented in response to the violation of 10 CFR 50.82(a)(8), to determine if HDI has taken appropriate measures to identify any previous inappropriate expenditures and prevent future occurrence. (Open Item 05000293/2024003-01, Review of Decommissioning Trust Fund Corrective Actions).
The Notice of Violation issued at IPEC identified that certain HDI corporate employee agreements contained language that would restrict or otherwise discourage employees from participating in protected activities as defined in 10 CFR 50.7(f). The subject documents were used at sites across the HDI fleet. The inspectors determined that revisions made to HDI employee agreements in use at PNPS were adequate to remove restrictive language and restore compliance with 10 CFR 50.7(f) and verified that employees who had previously signed agreements with restrictive language were sent letters clarifying their rights to provide information to the NRC.
c. Conclusions
No violations of more than minor safety significance were identified.
4.0
Exit Meeting Summary
On October 24, 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
SUPPLEMENTAL INFORMATION
ITEMS OPEN, CLOSED, AND DISCUSSED
Opened
Section
Summary
2.1b
Review of
Decommissioning Trust Fund
Corrective Actions
PARTIAL LIST OF DOCUMENTS REVIEWED
Drawing No. M287, Rev. 43-Plant Ventilation Diagram
Drawing No. M233 SH1, Rev. 36-Clean Radwaste System
Drawing No. M234, Rev. 40- Reclaimable Radwaste System
Radiological Survey Nos. 2024-0543, 2024-0951, 2024-0270, 2024-0271, 2022-1334, 2024-
0573, 2024-0287, 2022-1044, 2023-1361, 2023-1075, 2023-0972
Radiological Survey Form #115, 4/20/21
IS-NSF-134, Rev. 23, Job Aid: Alternative Security Measures for Industrial Security/Part 37
Areas
Pilgrim Station Part 37 Security Plan, Rev. 04
Memorandum of Understanding with Plymouth Police Department, 2023
P-EN-FAP-OM-028 Decommissioning Change Management
6.1-222, Rev. 3, Radiological Technical Evaluations and Calculations
Sealed Source Leak Test Datasheet, February 2024
P-EN-RP-121, Rev. 21, Radioactive Material Control
P-EN-RP-143, Rev. 18, Source Control
DSP-IO-AA-001, Rev. 1, Unescorted Access Authorization Program
IS-1.06, Rev. 3, Industrial Security Patrols
IS-2.01, Rev. 6, Station Access Control
IS-228, Rev. 0, Security Seal of Category 1 and Category 2 Material
24 Self-Assessment of Access Authorization and Fitness for Duty for ISFSI and Part 37
Decommissioning Sites
PIL-2023-01 Part 37.55 Security Program Review Checklist
Part 37 Security Plan Read-and-Sign List, RP Department, 2024
Annual Part 37 Security Training Logs, 2024
Part 37 2024 Annual Training PowerPoint
10CFR37 Category 1 and 2 RAM Accountability Log, April-June 2024
IS-8.31, Rev. 4, Operational Inspection and Testing of Part 37 Security Zones and Industrial
Security Equipment
Reactor Vessel Head Characterization
PNPS Defueled Safety Analysis Report (DSAR), Rev. 4
PNPS Offsite Dose Calculation Manual (ODCM), Rev. 17
P-EN-CY-111, Rev. 9, Radiological Groundwater Protection Program
Teledyne Brown Engineering Environmental Services Quality Assurance Reports, 3Q23 - 4Q24
Procedure 8.E.8 Attachment 3, Reactor Building Vent Instrument Calibration, July 2023
Work Order PIL-WO-50078363-02-03, Perform quarterly partial calibration of RBV sample flow
indicator
Procedure 8.M.3-16, Reactor Building Gas and Sample Flow Functional Test, 4/2024 and
7/2024
P-EN-CY-130-07, Radiological Environmental Monitoring Program
EC-PNP-2023-062 Install RBV Flow Indication
Groundwater Monitoring Results 2019-2024
Issue Report PIL-07289
HDI Reply to a Notice of Violation EA-24-037
HDI Separation and Release Agreement - UWUA, Revised 4-16-24
HDI Waiver and Release Agreement, Revised 4-16-24
Holtec International Form 11HR, Confidentiality, Non-Compete, and Non-Solicitation
Agreement, Revised 4-16-24
Holtec Security International, LLC Form 11HR-HSI, Confidentiality, Non-Compete, and Non-
Solicitation Agreement, Revised 4-16-24
Holtec International Form 93HR, Pledge of Ethical Conduct
HDI and HSI Separation Checklist
HDI letter Comprehensive Decommissioning International Separation and Release Agreement
and Your Rights to Engage in NRC-protected Activities
LIST OF ACRONYMS USED
Agency-wide Document and Access Management System
AOG
Augmented Off-Gas
Annual Radiological Environmental Operating Report
Annual Radiological Effluent Release Report
Corrective Action Program
CFR
Code of Federal Regulations
Entergy Nuclear Operations, Inc
GPO
Government Printing Office
Holtec Decommissioning International, LLC
IMC
Inspection Manual Chapter
Indian Point Energy Center
IR
Issue Report
Independent Spent Fuel Storage Installation
NRC
U.S. Nuclear Regulatory Commission
Offsite Dose Calculation Manual
Pilgrim Nuclear Power Station
Reactor Building Vent
Radiological Environmental Monitoring Program
Radiation Protection
Thermoluminescent Dosimeter