IR 05000302/2016003

NRC Inspection Report 05000302/2016003, Duke Energy Florida, Inc., Crystal River Unit 3, Crystal River, Florida

ML16342A961
Person / Time
Site:	Crystal River
Issue date:	12/06/2016
From:	Racquel Powell NRC/RGN-I/DNMS/NMSB1
To:	Hobbs T Duke Energy Florida
References
IR 2016003
Download: ML16342A961 (10)

Text

ber 6, 2016

SUBJECT:

NRC INSPECTION REPORT NO. 05000302/2016003, DUKE ENERGY FLORIDA, INC., CRYSTAL RIVER UNIT 3, CRYSTAL RIVER, FLORIDA

Dear Mr. Hobbs:

On November 10, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an on-site inspection under Inspection Manual Chapter 2561, Decommissioning Power Reactor Inspection Program," at the permanently shut down Crystal River Nuclear Plant Unit 3 (CR-3). The inspector examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and the conditions of your license. The inspection consisted of observations by the inspector, interviews with personnel, and a review of procedures and records. The results of the inspection were discussed with you and other members of the CR-3 staff on November 10, 2016, and are described in the enclosed report.

No findings of safety significance were identified.

In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter, its enclosure(s), and your response 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 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). No reply to this letter is required. Please contact Steve Hammann, at 610-337-5399, if you have any questions regarding this matter.

Sincerely,

/RA/

Raymond Powell, Chief Decommissioning and Technical Support Branch Division of Nuclear Materials Safety Enclosure: Inspection Report 05000302/2016003 cc w/encl: Distribution via ListServ

EXECUTIVE SUMMARY

Duke Energy

Crystal River Nuclear Plant NRC Inspection Report No. 05000302/2016003 An announced CR-3 decommissioning on-site inspection was performed November 8-10, 2016.

The inspection included a review of site safety reviews and modifications, self-assessments and corrective actions, and the CR-3 biennial emergency preparedness (EP) exercise. The inspection consisted of observations by the inspector, interviews with Duke Energy personnel, a review of procedures and records, and plant walk-downs. The NRC's program for overseeing the safe operation of a shut-down nuclear power reactor is described in Inspection Manual Chapter (IMC) 2561, Decommissioning Power Reactor Inspection Program."

Based on the results of this inspection, no findings of safety significance were identified.

ii Inspection Report No. 05000302/2016003

REPORT DETAILS

1.0 Background On February 20, 2013, Duke Energy sent a letter [Agency Documentation and Management System (ADAMS) Accession Number ML13056A005] to the NRC certifying the permanent cessation of activities and certifying that the fuel had been permanently removed from the reactor. This met the requirements of 10 Code of Federal Regulations (CFR) 50.82(a)(1)(i) and 50.82(a)(1)(ii). CR-3 is currently in the SAFSTOR phase of decommissioning as described in IMC 2561.

2.0 SAFSTOR Performance and Status Review

a. Inspection Scope

[Inspection Procedures (IPs) 37801, 40801]

The inspector conducted document reviews and interviews with plant personnel to verify Duke Energy procedures and processes conformed to the regulations and guidance associated with 10 CFR 50.59 and that changes made by Duke Energy under 10 CFR 50.59 did not require prior NRC approval. The inspector reviewed the qualification and training for 10 CFR 50.59 evaluators. The inspector also reviewed Duke Energys activity screening process that is used to determine if an evaluation is needed. The inspector reviewed two 10 CFR 50.59 evaluations. The first evaluation was for the abandonment of the seismic monitoring instrumentation. The second evaluation was for a change to the amount of water necessary in the cask loading area of the spent fuel pool during dry cask operations.

The inspector reviewed documents and interviewed personnel to verify that Duke Energy management performed audits and self-assessments, and ensured issues were identified and corrected in accordance with the sites corrective action program (CAP).

The inspector reviewed a representative selection of CAP documents to determine if a sufficiently low threshold for problem identification existed, follow-up evaluations were of sufficient quality, and Duke Energy assigned appropriate prioritization for issue resolution commensurate with the significance of the issue. The inspector reviewed an audit of the Radioactive Effluent and Radioactive Waste programs and reviewed meeting minutes of the Station Performance Oversight Committee. The inspector also observed members of the Nuclear Oversight (NOS) organization in the field performing oversight of contractor work activities.

b. Observations and Findings

The inspector determined that 10 CFR 50.59 screenings and evaluations are being performed and that Duke Energy has trained and qualified individuals to perform the evaluations. The inspector determined that changes under 10 CFR 50.59 did not require prior NRC approval and safety reviews were performed for design changes and modifications in accordance with applicable regulatory requirements, license conditions and the Final Safety Analysis Report.

Inspection Report No. 05000302/2016003

The inspector determined that issues were being identified and entered into the CAP in a timely manner and the issues were effectively screened, prioritized and evaluated commensurate with their safety significance. The inspector verified audits were being performed by qualified individuals independent of the organization being audited and that management reviewed the audits and associated corrective actions. The inspector verified NOS continues to perform oversight of decommissioning activities.

c. Conclusions

Based on the results of this inspection, no findings of safety significance were identified.

3.0 Decommissioning Emergency Preparedness Scenario Review and Exercise Evaluation

a. Inspection Scope

IP 82401 The inspector performed an on-site inspection on November 8, 2016, of the biennial EP exercise to assess the adequacy of Duke Energys conduct of the exercise and its capability to assess emergency response organization (ERO) performance via a formal critique process. Prior to the EP exercise, the inspector conducted an in-office review of the exercise objectives and scenario to determine if the exercise would provide sufficient opportunities to demonstrate the EROs capability to perform key skills to protect public health and safety.

The exercise evaluation consisted of observation and assessment of Duke Energys performance in the biennial exercise and the overall adequacy of Duke Energys ERO.

The following areas were also reviewed: EROs recognition of abnormal plant conditions; command and control; intra-and inter-facility communications; prioritization of mitigating activities; notification of offsite agencies; and the overall implementation of the emergency plan and its implementing procedures. Following the exercise, the inspector observed Duke Energys drill critique to ensure that weaknesses were being properly identified. Additionally, the inspector performed a review of past performance issues from previous Duke Energy EP drill reports to determine the effectiveness of licensee corrective actions as demonstrated during the exercise and to ensure compliance with NRC requirements.

b. Observations and Findings

The inspector noted that the scenario developed by Duke Energy was plausible based on current plant conditions and that it included opportunities that allowed for the demonstration of proficiency in key skills necessary to implement the principle functional areas of emergency response.

Inspection Report No. 05000302/2016003

The inspector performed independent observations of ERO performance in the control room and emergency support center, including the performance of the emergency coordinator, emergency mitigation coordinator, communicator, and radiation controls coordinator. Duke Energys critique process identified areas for improvement. The inspector verified that the areas for improvement were entered into the CAP.

Additionally, the inspector determined that the areas for improvement identified were minor in nature and would not impact Duke Energys ability to implement their emergency plan in the event of an actual radiological emergency.

c. Conclusions

Based on the results of this inspection, no findings of safety significance were identified.

4.0

Exit Meeting Summary

On November 10, 2016, the inspector presented the inspection results to Terry Hobbs, Decommissioning General Manager, and other members of Duke Energys staff. The inspector confirmed that proprietary information was not removed from the site.

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PARTIAL LIST OF PERSONS CONTACTED Licensee B. Akins, Radiation Protection and Chemistry Manager C. Burtoff, Lead RP P. Dixon, Decommissioning Technical Support Manager B. Ferguson, Emergency Planning T. Hobbs, Decommissioning General Manager J. Lane, Systems Engineer P. Rose, Licensing K. Shelton, RP Supervisor M. Van Sicklen, Licensing I. Wilson, Ops/Maintenance Manager ITEMS OPEN, CLOSED, AND DISCUSSED None LIST OF

DOCUMENTS REVIEWED

Audits and Reports

Audit Closeout Memorandum, NOS-2016-066, dated April 7, 2016

Crystal River Nuclear Plant, Critique of the 2014 Biennial Radiological Emergency Response

Plan Evaluated Exercise, November 04, 2014

Crystal River Nuclear Plant, Critique of the May 5, 2015 Full Scale PDEP Drill

Crystal River Nuclear Plant, Critique of the August 11, 2015 PDEP Drill

Crystal River Nuclear Plant, Critique of the November 03, 2015 PDEP Annual ERO Exercise

Crystal River Nuclear Plant, Integrated ERO Training Drill Critique, August 23, 2016

Nuclear Oversight Audit, 2016-CR3-REW-01, CR3 Radioactive Effluent and Radioactive Waste

CRs

00742756, 00752570, 02025332, 01958752, 02024580, 02064728, 02043565, 02034167,

00716963, 00716972, 02061123, 02061125, 02061129, 02061134

Procedures

AD-NO-ALL-0102, Audit System Design, Rev. 1

AD-NO-ALL-0111, Independent Review Program, Rev. 0

AD-NO-ALL-0303, NOS Follow-Up, Rev. 2

AD-NO-ALL-0305, Integrated Scheduling of Audits and Assessments, Rev. 2

AD-NO-ALL-0601, Auditor and Assessor Training and Certification Program, Rev. 3

AD-NO-ALL-1001, Conduct of Audit, Rev. 3

AI-4000, Conduct of the Emergency Planning Coordinator and Schedule for Permanently

Defueled Emergency Plan Maintenance, Rev. 20

AI-4001, Conduct of Drills and Exercises Supporting the Permanently Defueled Emergency

Plan, Rev. 7

CAP-0200, Conduct of Performance Improvement, Rev. 3

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Procedures (Contd)

EM-205, Personnel Emergency Responsibilities Regarding Discovery, Assembly, Evacuation,

and Accountability Within the Protected Area, Rev. 35

EM-206, Emergency Response Organization Notification, Rev. 111

EM-500, Equipment Important to Emergency Preparedness and Response, Rev. 3

EM-501, Operation of the Emergency Support Center (ESC), Rev. 0

EM-502, Conduct of the Emergency Coordinator, Rev. 3

EM-503, Conduct of the Emergency Mitigation Coordinator, Rev. 0

EM-504, Conduct of the Radiation Controls Coordinator, Rev. 0

HPP-334, Off-Site Radiation Monitoring and Control, Rev. 1

HPP-409, Inventory and Availability of Emergency Supplies/Equipment, Rev. 34

NOS-1000, CR3 Nuclear Oversight - Conduct of Operation, Rev. 1

OP-421C, Operation of the Auxiliary Building Overhead Crane FHCR-5, Rev. 46

REG-0010, 10 CFR 50.59 and Selected Regulatory Reviews, Rev. 4

Miscellaneous

Crystal River Nuclear Plant, ERO Biennial Evaluated Exercise, November 08, 2016

Crystal River Unit 3, Permanently Defueled Emergency Plan, Rev. 3

Crystal River Unit 3, Permanently Defueled Emergency Action Level Bases Manual, Rev. 1

November 8, 2016 Exercise Message Cards, Timeline, and SFP Data

NPOP 2014-002, NOS Nuclear Project Oversight Plan for Crystal River 3 Dry Fuel Storage

Project, Rev. 2

Station Performance Oversight Committee Meeting Minutes, September 13, 2016

LIST OF ACRONYMS USED

CAP Corrective Action Program

CFR Code of Federal Regulations

CR-3 Crystal River Unit 3

Duke Energy Duke Energy Florida, Inc.

EP Emergency Preparedness

ERO Emergency Response Organization

IMC Inspection Manual Chapter

IP Inspection Procedure

NRC U.S. Nuclear Regulatory Commission

NOS Nuclear Oversight

Inspection Report No. 05000302/2016003