IR 05000302/2023002
| ML24108A031 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 04/17/2024 |
| From: | Anthony Dimitriadis NRC Region 1 |
| To: | Reid B ADP CR3 |
| References | |
| IR 2023002 | |
| Download: ML24108A031 (1) | |
Text
April 17, 2024
SUBJECT:
ACCELERATED DECOMMISSIONING PARTNERS (ADP) CR3, LLC, CRYSTAL RIVER UNIT 3 - NRC INSPECTION REPORT NO. 05000302/2023002
Dear Billy Reid:
On December 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 walk-downs. The results of the inspection were discussed with you and other members of your staff on March 10, 2024, 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 05000302/2023002 w/Attachment
cc w/encl:
Distribution via ListServ ANTHONY DIMITRIADIS Digitally signed by ANTHONY DIMITRIADIS Date: 2024.04.17 14:09:12 -04'00'
EXECUTIVE SUMMARY
Accelerated Decommissioning Partners CR3, LLC (ADP)
Crystal River Unit 3 NRC Inspection Report No. 05000302/2023002
A routine announced decommissioning inspection was completed on December 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 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 February 20, 2013, Duke Energy sent a letter [Agency Documentation and Management System 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.
2.1 Inspection Procedures 37801, 40801, 71801, 83750, 84750, 86750, 93100
a. Inspection Scope
The inspectors performed on-site inspection activities on June 19-22, 2023, September 25 - 28, 2023, and December 11 - 14, 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 entered 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 walk-downs to assess field conditions and decommissioning activities by observing material condition of structures, systems, and components, housekeeping, system configurations, radiological postings, and evaluating worker level of knowledge or procedure use and adherence. The walk-downs included the reactor and auxiliary buildings, and a general outside area walk-down. The inspectors observed activities, reviewed documentation, and interviewed personnel associated with occupational radiation exposure to evaluate the licensees protection of worker health and safety and radiological protection department staffing. The inspectors conducted site walk-downs of radiologically controlled areas, to examine radiological postings, and airborne area controls.
The inspectors observed select pre-job briefings and associated work activities, including reactor vessel segmentation, let-down cooler removal, resin liner lift, miscellaneous waste storage tank removal, and blade change-out during reactor vessel segmentation. The inspectors reviewed radiation work permits (RWPs), As Low As Reasonably Achievable (ALARA) work plans to determine if radiation work activities were effectively pre-planned to limit worker exposure. The inspectors also observed Radiation Protection (RP) technicians and supervisors perform work activities such as conducting surveys of decontaminated surfaces and surveys of areas for loose contamination. Additionally, the inspectors observed RP coverage during the following work activities: let-down cooler removal, resin liner lift, reactor vessel segmentation, spent fuel pool liner demolition, and segmented reactor vessel removal. During the inspectors walk-downs of the reactor building and auxiliary building, various instruments were checked for their operating condition and calibration.
The inspectors reviewed activities and documentation associated with radioactive effluent control and site Radiological Environmental Monitoring Program (REMP) to assess the effectiveness of site radiological programs. The inspectors reviewed changes made to the Offsite Dose Calculation Manual (ODCM), Process Control Program (PCP), and the radioactive waste system design and operation. The inspectors reviewed radioactive gaseous and liquid effluent release permits, and licensee audits. The inspectors reviewed procedures associated with entering events into the files required per 10 CFR 50.75(g) and assessed their adequacy.
The inspectors observed a selection of environmental monitoring stations to evaluate their location, placement, and material condition and observed several air sampling stations and walked down several locations of groundwater monitoring wells.
The inspectors reviewed documents and conducted interviews with plant personnel to determine if ADP procedures and processes were adequate and in accordance with the regulations and guidance associated with 10 CFR 50.59, and to determine if changes made by ADP under 10 CFR 50.59 required prior NRC approval.
The inspectors observed activities, interviewed personnel, performed walk-downs, and reviewed documentation to assess the effectiveness of the sites programs for the handling, storage, and transportation of radioactive material and waste. The review included records of shipment packaging, surveys, labeling, marking, placarding, vehicle checks, and emergency instructions to determine compliance with the applicable NRC and Department of Transportation regulations.
The inspectors observed a shipment of resin that was departing from the site.
The inspectors reviewed documentation and discussed with ADP and Duke Energy the overall financial status of decommissioning for Crystal River and evaluated the use of decommissioning trust funds to determine if they were appropriately used in accordance with regulatory requirements. The inspectors also discussed any significant changes to the estimated cost for, and any potential significant delays to, the decommissioning schedule.
Safety culture assessors conducted interviews and reviewed documentation for safety conscious work environment (SCWE). The assessment included focus groups and interviews, reviewing employee concern program (ECP) personnel procedures and files and reviewed the 2022 and 2023 safety culture surveys.
b. Observations
The inspectors noted that during this inspection period, the site continued decommissioning and dismantlement activities in the reactor building, turbine building, and auxiliary building. The inspectors observed samples of the following activities: completion of reactor vessel segmentation, reactor vessel grouting, and continued dismantlement on the spent fuel pool floor in the auxiliary building. The inspectors noted that for areas of the plant toured, the material condition and housekeeping was adequate. The inspectors noted through plant walk-downs, document reviews, and in-field observations, that ADP staff had conducted activities in accordance with the regulatory requirements. The inspectors conducted a walk-down of the auxiliary building as closed demolition was being conducted to determine if the appropriate radiological and industrial hazards were adequately addressed to ensure compliance with regulatory requirements. The inspectors noted that pre-job briefings were thorough and highlighted the appropriate specific safety concerns, and that workers were knowledgeable of and adhered to plant procedures and work plans. The inspectors determined that site staffing was adequate, and personnel qualifications and training were appropriate and up to date.
The inspectors determined that screenings and evaluations had been properly performed in accordance with the requirements outlined in 10 CFR 50.59 and that ADP had trained and qualified individuals to perform the evaluations. Of note, the inspectors reviewed the evaluation to change ventilation of the reactor building and auxiliary building to a temporary ventilation system.
The inspectors reviewed the technical justification to ensure the proper air flow was adequate and conducted a walk-down of the system to ensure the system description was appropriate. The inspectors determined that the selected changes made under 10 CFR 50.59 did not require prior NRC approval and safety reviews were performed for design changes and modifications were in accordance with applicable regulatory requirements, license conditions and the Decommissioning Safety Analysis Report. Based on reviews and interviews with site personnel, the inspectors noted that reviews under 10 CFR 50.59 would continue through the calendar year 2024 as the site continues active decommissioning and demolition.
The inspectors determined that issues had been identified, evaluated and entered into the CAP, were commensurate with their safety significance.
The inspectors verified that the RWPs, ALARA work plans, and micro-ALARA plans were implemented to limit worker exposure. The inspectors determined that RP staff effectively controlled observed work activities and used appropriate equipment during those work activities.
The inspectors verified that selected technician training and qualifications were up to date.
Inspectors noted during the liner movement, RP personnel conducted continuous instrument dose rate measurements, had effective communication for individuals to move to low dose areas, and had proper controls during the movement such as postings and identifying the magnitude and extent of the radiological hazard. The inspectors also observed RP personnel conducting air sampling while cutting of contaminated piping in the reactor building. The inspectors determined that the licensee plans for the work were commensurate with the risk significance of the work and associated hazards. The inspectors verified that selected instruments during walk-downs were in calibration and in proper working condition.
The inspectors reviewed financial assurance documentation, including the annual report on the status of decommissioning funding, and met with site staff to determine whether the funds were used in accordance with the regulatory requirements and if any changes could significantly impact the sites decommissioning financial assurance. The inspectors determined that the licensee has used funds in accordance with regulatory requirements and have no significant deviations from the decommissioning schedule.
The NRC safety culture assessors interviewed approximately 59 employees from the Radiation Protection Departments as well as employees from NorthStar and Orano who had participated in the demolition work; the subcontractors supporting that work; the ECP managers from both NorthStar and Orano, as well as the employees from Orano TN which is formally issued the ISFSI license. The majority of the employees that the safety culture assessors interviewed indicated that they were encouraged to raise concerns and would do so through most avenues without fear of retaliation. The majority of personnel interviewed stated that the ECP programs for both Orano and NorthStar were viewed favorably and would be useful avenues for raising concerns, if needed. Additionally, everyone interviewed indicated that knew about the NRC and how to contact the NRC with concerns, if needed. The assessors heard from the vast majority of the people interviewed that they had the authority to stop work and were not hesitant to use it.
The assessors received feedback that the most recent layoffs and Reductions-In-Force (RIFs) did not appear to have caused negative perceptions about raising concerns, however, there were opportunities for improvement for enhanced communications about RIFs, and the process for reducing staff in order to ensure that perceptions about raising concerns associated with RIFs did not change.
Additionally, the assessors received information during the interviews that the line organizations from both Orano and NorthStar indicated that they had adequate staffing, resources, and tools to complete their work and had been told by management that if they needed something, they could ask for it. The assessors determined that there was good stability within the organizations, resulting in minimal turnover of the line organization or supervisors, and that led to a lot of trust among the ranks and confidence that concerns raised would be addressed.
However, the assessors received concerns in the area for environment for raising concerns safety culture trait. Some personnel that supported Orano stated some hesitancy about raising concerns, particularly to the NRC. In addition, the staff raising such concerns who supported Orano stated that they didnt always feel they could stop work. The staff raised these concerns because of comments that had been made to the employees implying that if they didnt get the work done, they would be replaced. This group also stated they were hesitant to approach the NRC with concerns because they perceived that they may be fired if they did.
The assessors received information that the NorthStar and Orano staff felt free to raise concerns through their management. However, they did not seem to be aware of the ECP or CAP programs or understood the definition of SCWE.
Based on the interviews and review of ECP files, the assessors concluded that management behaviors within NorthStar Senior Management have caused a Chilled Work Environment with personnel who have nuclear regulatory responsibilities in both NorthStar and Orano. This is based on a perception that personnel are not free to raise safety concerns using all available avenues without fear of retaliation, specifically fear that they may lose their jobs or be demoted as a result of raising concerns. Communications from Orano to ADP CR-3 in November 2022 provided ADP CR-3 with information concerning a respectful work environment and a potential chilled environment. However, based on the assessors review, it did not appear that any definitive actions had been taken to resolve the concerns that were raised to ADP CR-3. The assessors observed that overall communications from the NorthStar management team had caused friction in some of the management ranks. These issues appear to be a continuation of or very similar to the safety culture issues that the NRC identified during the previous safety culture inspection in 2021 (ML21313A344) that may have progressed to chill the employees willingness to raise concerns to senior management at the site. The NRC will continue to monitor the environment at CR-3 in future inspections.
The majority of the line organization interviewees indicated that people were treated fairly and respectfully by management and peers, which is contrary to what was shared by the higher-level personnel. Employees from NorthStar, Orano, and other contractors expressed that they felt encouraged to work together and interviewees indicated that there was good coordination, teamwork, and camaraderie between the organizations.
c. Conclusions
No violations of more than minor safety significance were identified.
3.0
Exit Meeting Summary
On March 10, 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/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
23 Annual Review Radiation Protection
Procedures
HPP-322A, Fastscan Calibration 2023, Revision 7
CH-230E, Energy and Efficiency Calibrations of HPGe detectors
HPS-2018, Response to a Contaminated Wound, Revision 1
HPS-201, Dosimetry Administration, Revision 1
HPP-307, Unmonitored Individual RCA Access, Revision 13
TRN1000, Decommissioning Training Program, Revision 6
Miscellaneous
QS-CR3-23-001, Preparations to Process and Transfer the Greater than Class C (GTCC)
Waste to the ISFSI
Health Physics Survey Record, #23-11-0010
Health Physics Survey Record, #23-10-0207
Health Physics Survey Record, #23-10-0256
Health Physics Survey Record, #23-10-0136
Health Physics Survey Record, #23-10-0171
ALARA Plan, RWP 238 & 242 - Task 3, Revision 2
SP0736L, Liquid Releases to the Discharge Canal, Revision 18
REG10-2023-002
REG10-2023-004
REG10-2023-005
N18-0003, Calculation of X/Q & D/Q, Revision 1
Reactor Vessel Hot Work Review Package
OR-CR3-23-018
Condition Reports
23000047
23000052
23000057
23000086
23000092
23000100
23000088
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-3
Crystal River Unit 3
Condition Review Group
D&D
Decommissioning and Demolition
DECON
Decommissioning
Duke Energy/DEF
Duke Energy Florida, Inc.
Employee Concerns Program
GPO
Government Printing Office
IMC
Inspection Manual Chapter
Independent Spent Fuel Installation
IR
Inspection Report
NRC
U.S. Nuclear Regulatory Commission
Offsite Dose Calculation Manual
Radiological Environmental Monitoring Program
RIF
Reductions-In-Force
Radiation Protection
Radiation Work Permit
Safety Conscious Work Environment