IR 05000302/2022003
| ML23144A034 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 05/25/2023 |
| From: | Anthony Dimitriadis Decommissioning, ISFSI, and Reactor Health Physics Branch |
| To: | Reid B ADP CR3 |
| References | |
| IR 2023001 | |
| Download: ML23144A034 (1) | |
Text
May 25, 2023
SUBJECT:
ACCELERATED DECOMMISSIONING PARTNERS (ADP) CR3, LLC,
CRYSTAL RIVER UNIT 3 - NRC INSPECTION REPORT NO. 5000302/2023001
Dear Billy Reid:
On March 31, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an 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 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 you and other members of your staff on April 11, 2023, and are described in the enclosed 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 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 Storm Veunephachan of my staff, at 610-337-5366, if you have any questions regarding this matter.
Sincerely, Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Radiological Safety and Security
Docket No.
05000302 License No.
Enclosure:
Inspection Report 05000302/2023001 w/Attachment
cc w/encl:
Distribution via ListServ Anthony M.
Dimitriadis Digitally signed by Anthony M. Dimitriadis Date: 2023.05.25 10:24:40 -04'00'
EXECUTIVE SUMMARY
Accelerated Decommissioning Partners CR3, LLC (ADP)
Crystal River Unit 3 NRC Inspection Report No. 05000302/2023001
An announced decommissioning inspection was completed on March 31, 2023, at the permanently shutdown Crystal River Unit 3 (CR3). The inspection included a review of design changes and modifications, corrective actions, occupational radiation exposure, safety conscious work environment, financial assurance, decommissioning performance and status reviews, fire protection, effluent monitoring, final status surveys, and solid radioactive waste management and transportation of radioactive materials. The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records, and plant walkdowns. 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 February 20, 2013, Duke Energy sent a letter [ADAMS Accession Number ML13056A005]
to the NRC certifying the permanent cessation of power operations and permanent removal of fuel from the reactor. This met the requirements of Title 10 of the Code of Federal Regulations. (10 CFR) 50.82(a)(1)(i) and 50.82(a)(1)(ii). On June 14, 2019, the NRC received a license transfer application [ML19170A209] and conforming amendment request filed by the Duke Energy Florida (DEF), LLC on behalf of itself and Accelerated Decommissioning Partners (ADP) CR3, LLC. The application sought NRC approval of the direct transfer of Facility Operating License No. DPR-72 for CR-3 and the general license for the CR-3 ISFSI from the current holder, DEF to ADP CR3, which is a wholly owned subsidiary of ADP, LLC, which the NRC approved on April 1, 2020 [ML20069A023]. On October 1, 2020, ADP and Duke Energy successfully completed the transaction.
CR-3 was inspected under the Actively Decommissioning (DECON), No Fuel in the Spent Fuel Pool category as described in IMC 2561 during this inspection period.
2.0 Active Decommissioning Performance and Status Review
2.1 Inspection Procedures 40801, 64704, 71801, 83750, and 86750
a. Inspection Scope
The inspectors performed on-site decommissioning inspections on January 17-19, 2023, January 23 - 26, 2023, and March 13 - 16, 2023 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 walk-downs.
The inspectors assessed the implementation and effectiveness of ADPs corrective action program (CAP) by reviewing a sampling of issues, non-conformances, and conditions adverse to quality into the CAP. The inspectors reviewed a representative selection of CAP documents and attended a Condition Review Group (CRG) meeting to determine if a sufficiently low threshold for problem identification existed, if follow-up evaluations were of sufficient quality, and if ADP assigned timely and appropriate prioritization for issue resolution commensurate with the significance of the issue.
The inspectors performed several plant tours to assess field conditions and decommissioning activities by surveying the material condition of structures, systems, and components, housekeeping, system configurations, and radiological postings. In addition, inspectors interviewed site staff to evaluate worker level of knowledge and procedure use and adherence.
These walkdowns included the reactor and auxiliary buildings and a general outside area walkdown. The inspectors observed select pre-job briefs and associated work activities, including Greater Than Class C (GTCC) processing activities, reactor cavity drain down, and the movement of a High Integrity Container (HIC) in the reactor building.
The inspectors evaluated Crystal Rivers Fire Protection Program (FPP) as it continues to change to determine if it meets commitments and NRC requirements such that no changes negatively affect the overall state of the FPP. The inspection consisted of interviews with site personnel, documentation review and plant walkdowns. The inspectors conducted walkdowns of fire areas, suppression systems, and fire department connections to assess the material condition and determine if it was adequately maintained.
The inspectors reviewed documentation and conducted observations associated with the possession, processing, and storage of radioactive materials, including GTCC. This included observing the process of loading GTCC from the reactor building and transportation to the independent spent fuel storage installation pad.
b. Observations
The inspectors determined that issues were generally identified, entered into the CAP, and evaluated commensurate with their safety significance with some exceptions. The inspectors reviewed the status of corrective actions associated with CR-2022000167, which documented NRC inspectors observation that corrective actions associated with Action 180477 for CR-2021000046 written on April 19, 2021, to review and revise licensing procedures, including CP0218, REG0010, REG0016, and REG0110. Action 236154 was assigned to prioritize, review, modify as necessary, and issue the procedures identified with a due date of May 31, 2023.
Discussions with site management indicated that contractual challenges as those described in NRC inspection report 2021003 (ML21313A344) were still impacting site activities. While the impact of procedure revision delay was determined to be of minor safety significance, if contractual challenges continue to be left unresolved, they could further impact regulatory activities.
The inspectors noted that for the areas of the plant toured, the material condition, housekeeping, and radiological posting and controls was adequate, with one exception. At the time of the inspection, there was a posted locked high radiation area (LHRA) on the reactor cavity floor in the reactor building around several garnet collection tanks and the associated waste filtration skid. The inspectors noted was a small opening between the handrails and the wall. After the inspectors identified the area, the licensee installed fencing material to cover the area as an immediate corrective action and entered the issue into the CAP as CR-2023000032. The inspectors noted that there was no evidence of any inappropriate entries into the area and the opening was relatively small.
The inspectors noted that during this inspection period, the site loaded two radioactive waste canisters (RWCs) with GTCC and placed them on the ISFSI pad. The inspectors observed portions of the GTCC loading campaign, including portions of the following: 1. The lifts of the transfer cask (TC) to the reactor cavity, the RWC into the TC, and the RWC and TC out of the reactor cavity and into the processing stand and 2. The welding and non-destructive evaluation of the root pass of the inner top cover and determined that the personnel were knowledgeable and procedures were followed. The inspectors observed the RWC transferred from the reactor building to the ISFSI pad and subsequent placement of the RWC into the horizontal storage module.
The inspectors reviewed a sampling of the Radiological Work Permit (RWP), As Low as Reasonably Achievable (ALARA) plan, and procedures related to the reactor cavity drain down work and determined that they were adequate to control occupational exposure and were executed as written with several exceptions described below.
CR3-CWP-ORANO-79B, GTCC Liner Waste Transfer to RWC-1 and RWC-2 Liners, dated September 13, 2022, required surveys of the shallow end, incore pit, and deep end to ensure no other GTCC waste needs to be placed in the RWC-2 liner prior to its closure. In response to NRC requests for surveys during the inspection, ADP determined that no survey was completed in the deep end to meet this requirement. After a notable delay, ADP entered this issue into its CAP as CR-2023000057 and took corrective actions, including performing surveys of the reactor cavity, which revealed 11 remnant GTCC pieces with contact dose rates up to 1254 R/hr. The inspectors noted that these pieces were identified after the RWC canisters loaded with GTCC were already processed and reactor cavity drain down had commenced. After characterization, ADP moved the remnant GTCC pieces into the reactor vessel for disposal. The inspectors noted that while the actual impact was negligible, it was fortuitous the issue was identified through NRC inspection activities prior to continued drain down.
RWP 242, Reactor Cavity Cleanup and Wash-down, Drain Down, and the associated ALARA plan required that the reactor cavity walls be pressure washed under water prior to drain down and a continuous air monitor be operating during work activities. During the inspection, drain down commenced without a continuous air monitor operating and without sufficient pressure washing. This resulted in contamination levels up to 20 mrad smearable contamination detected on the initial section of the walls exposed by drain down. ADP entered this issue into its CAP as 2023000036 and took immediate corrective actions, including stopping drain down activities and performing decontamination activities of the walls in an attempt to reach a goal several orders of magnitude lower. The inspectors noted that ADP did not detect any significant increase in airborne activity on the grab air sampler nor any significant spread of contamination from contamination large area smears of the floor. The ALARA plan states that drying the cavity could create a risk of airborne activity and prescribes pressure washing to reduce the potential source term off the walls. The NRC inspectors noted the potential existed for significant airborne activity given the potential contamination levels on the walls from reactor vessel internals segmentation.
Through walkdowns and interviews, Crystal Rivers fire protection was determined to be adequate and maintained in accordance with NRC requirements and applicable fire protection plan. Manual fire suppression storage locations were observed within the auxiliary building, turbine building, and reactor building. Those items included but not limited to fire extinguishers, fire barriers, and transient combustibles.
ADP maintained the leadership, staffing, and training of the onsite incipient fire brigade. Review of training documents and fire hazard analysis were determined to be adequate. Agreements were appropriately established with the local fire department to be the primary responder for onsite fires. Procedures were appropriately established ensuring the timely response and coordination with offsite responders. The inspectors verified that offsite responders received training on facility layout, fire hazards, pre-fire plans, firefighting equipment, radiological hazards, and health physics relevant to firefighting operations.
c. Conclusions
No violations of more than minor safety significance were identified.
3.0
Exit Meeting Summary
On April 11, 2023, the inspectors presented the inspection results to Billy Reid, Site Vice President, and other members of the CR-3 staff. No proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
- B. Reid, Site Vice President
- B. Akins, Radiation Protection Manager
- J. Jernigan, Decommissioning Licensing Manager
- G. McCallum, D&D Site Manager
- H. Van Sicklen, ISFSI Licensing Manager
- L. McDougal, ORANO Project Manager
- T. Doruff, Work Control Manager
- N. Lagum, Decommissioning Director
- C. Burtoff, Radiation Protection Engineer
ITEMS OPEN, CLOSED, AND DISCUSSED
None
PARTIAL LIST OF DOCUMENTS REVIEWED
Audits
CMPR-CR3-2022 IMA Report
Procedures
CR3-FPP-039, Fire Protection Plan, Revision 39
21 Fire & EMS Updated
CR3-Fire Hazard Analysis, Revision 19
ALARA Plan, Decontaminated Reactor Cavity After Drain-down, January 18, 2023
RWP 242, Reactor Cavity Cleanup and Wash-down, Drain Down, January 24, 2023
ALARA Plan, Reactor Vessel/Reactor Vessel Internals (RV/RVI) Segmentation and Removal,
October 11, 2022
CAP-0200, Corrective Action Program Crystal River Unit 3, Revision 6
CR3-CWP-ORANO-079B, GTCC Liner Waste Transfer to RWC-1 & RWC-2 Liners,
November 30, 2022
COR-DDOPS.CR3-00041-000, Crystal River 3 Decommissioning - RWC Lessons Learned,
February 2, 2023
Crystal River Unit 3 Technical Specifications, Amendment 261
Health Physics Survey Record 23-02-0243, Lower Cavity Floor, February 23, 2023
Health Physics Survey Record 23-02-0217, Reactor Shallow Cavity, February 20, 2023
Health Physics Survey Record 23-02-0247, Collecting/Surveying Misc. Items in Deep End
underwater, February 23, 2023
22 Fire Protection Self-Assessment
Condition Reports
22000157
22000104
22000095
22000091
22000073
22000007
LIST OF ACRONYMS
Agencywide Document and Management System
Accelerated Decommissioning Partners
As Low As Reasonably Achievable
Corrective Action Program
CFR
Code of Federal Regulations
CR
Condition Report
Condition Review Group
CR-3
Crystal River Unit 3
DECON
Decommissioning
Duke Energy/DEF
Duke Energy Florida, Inc.
FFP
GPO
Government Printing Office
Greater-Than-Class-C
High Integrity Container
IMC
Inspection Manual Chapter
Independent Spent Fuel Installation
NRC
U.S. Nuclear Regulatory Commission
Radiation Protection
Radioactive Waste Canisters
Radiological Work Permit
Transfer Cask