IR 05000305/2025002
| ML25210A080 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  (DRP-043) |
| Issue date: | 08/04/2025 |
| From: | Dave Hills NRC/RGN-III/DRSS |
| To: | Worster R Kewaunee Solutions |
| References | |
| IR 2025002 | |
| Download: ML25210A080 (1) | |
Text
SUBJECT:
KEWAUNEE POWER STATION - NRC INSPECTION REPORT NO. 05000305/2025002(DRSS)
Dear Ronald Worster:
On July 17, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Kewaunee Power Station (KPS). On July 24, 2025, the NRC inspectors discussed the results of the inspection with you and members of your staff. The results of this inspection are documented in the enclosed report.
During the inspection, the NRC inspectors reviewed the onsite activities associated with the Problem Identification and Resolution at PSRs, Decommissioning Performance and Status Review at Permanently Shut down Reactors, Occupational Radiation Exposure at Permanently Shut down Reactors, Remedial and Final Surveys at Permanently Shut down Reactors, Radioactive Waste Treatment and Effluent Environmental Monitoring, and Material Control and Accounting. The inspection consisted of an examination of activities at the site as they related to safety and compliance with the Commissions rules and regulations.
No violations of more than minor safety significance were identified during this inspection.
August 4, 2025 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (CFR)
2.390 Public Inspections, Exemptions, Requests for Withholding.
Sincerely, David E. Hills, Chief Decommissioning, Reactor, and ISFSI Health Physics Branch Division of Radiological Safety and Security Docket No.: 50-305 License No.:DRP-43
Enclosure:
IR No. 05000305/2025002(DRSS)
REGION III==
Docket No.:
50-305 License No.:
DRP-43 Report No.:
05000305/2025002 Licensee:
Kewaunee Solutions Facility:
Kewaunee Power Station Location:
Kewaunee, Wisconsin Inspection Dates:
April 14-16, 2025 May 12-15, 2025 June 9-12, 2025 July 10, 2025 July 14-17, 2025 Inspectors:
M. LaFranzo, Sr. Health Physicist B. Lin, Sr. Health Physicist P. Lee, Ph. D., CHP, Health Physicist N. Audia, Reactor Inspector Approved By:
David E. Hills, Chief Decommissioning, Reactor, and ISFSI Health Physics Branch Division of Radiological Safety and Security
EXECUTIVE SUMMARY
[Kewaunee Power Station]
NRC Inspection Report No. 05000305/2025002 This U.S. Nuclear Regulatory Commission (NRC) inspection was a routine, announced inspection of decommissioning activities being conducted at the facility. A brief summary of the areas reviewed are described below. Based on the results of the inspection, no cited violations were identified.
Problem Identification and Resolution at PSRs Issues were identified by the licensee at appropriate thresholds and entered into the Corrective Action Program (CAP). Issues were screened and prioritized commensurate with safety significance. Licensee evaluations determined the significance of issues and included appropriate remedial corrective actions.
Individuals at Kewaunee are comfortable with raising safety concerns. Kewaunee had recognized a few areas to strengthen its safety culture and are actively working in the areas.
Decommissioning Performance and Status Review at Permanently Shut down Reactors The inspectors determined that decommissioning activities were in accordance with the regulations and license requirements.
Occupational Radiation Exposure at Permanently Shut down Reactors Adequate protection of worker health and safety from exposure to radiation and radioactive material was provided. Decommissioning activities were executed in general alignment with planning documents and as provided in RWPs and As Low As Reasonably Achievable (ALARA) reviews. Radiation surveys were performed adequately to identify the hazards present.
Remedial and Final Surveys at Permanently Shut down Reactors Adequate protection of the public health and safety from exposure to radiation and radioactive material was provided.
Radioactive Waste Treatment and Effluent Environmental Monitoring The liquid and gaseous effluent sampling program was effective at quantifying radioactive effluent releases and was implemented in accordance with applicable procedures.
Material Control and Accounting The licensees program was intended to control and account for all Special Nuclear Material (SNM) on-site, as well as detect any loss or unauthorized diversion of SNM in a timely manner. The licensee had implemented an adequate program to inventory and control the SNM on-site. Overall, the licensee had implemented the Material Control and Accounting (MC&A) program in accordance with the regulations.
Report Details Summary of Facility Status The KPS is a permanently shut-down and defueled power reactor undergoing active decommissioning. During this inspection period, the licensee was conducting routine decommissioning activities.
1.0 Problem Identification and Resolution at PSRs (IP 40801)
1.1 Inspection Scope The purpose of this portion of the inspection was to evaluate 1) the effectiveness of licensee controls to identify, resolve, and correct issues, 2) the audit and assessment programs, and 3) management reviews of the safety conscious work environment.
The inspectors performed walkdowns, reviewed documents, and interviewed plant personnel to assess the licensees performance in the following areas:
1.2 Observations and Findings The inspectors assessed the Corrective Action Program (CAP) effectiveness, which was accomplished through a combination of interviews and a review of corrective action documentation since 2023. The inspectors concluded that the licensees implementation of the CAP was generally effective and supported nuclear safety.
Based on the samples reviewed and the interviews held, the inspectors concluded that Kewaunee Solutions continued to identify issues at a low threshold and appropriately entered the issues into the CAP. The licensee usually entered issues into the CAP completely and accurately. Additionally, the inspectors determined that the site was generally effective at prioritizing issues within the CAP, and at implementing appropriate corrective actions.
Furthermore, the inspectors assessed Kewaunees use of internal and industry operating experience. The inspectors determined that the licensees utilization of operating experience was generally effective. Relevant operating experience was being reviewed by the site for applicability and was communicated to the appropriate staff for implementation. This review was performed through a review of the sites operating experience procedures, documents placed in the sites corrective action program for applicable Nuclear Regulatory Commission Generic Communications, and an interview with an individual responsible for licensee operating experience.
The inspectors also determined that the licensees audits were generally effective and performed in accordance with site procedures. The licensee periodically conducted audits throughout the organization in accordance with its schedule, and the audits were generally effective at identifying issues and opportunities for improvement at an appropriate threshold.
Finally, the inspectors assessed Kewaunees safety culture by conducting interviews, behavioral observations, and document reviews. The inspectors conducted a total of 22 individual interviews that covered all aspects of the work force across Kewaunee Solutions. In general, the inspectors independent safety culture assessment confirmed the results of Kewaunees own safety culture surveys. The general consensus among the interview participants was that the safety culture at Kewaunee Solutions was relatively consistent through 2024. However, at the beginning of 2025, the safety culture at the site had changed due to an influx of personnel that were new to the nuclear work culture. Most participants perceived that there had been an increase in leadership efforts to communicate the importance of a safe work environment and the focus on safety over production over approximately the past year. Participants noted that the site had put an emphasis on procedure use and adherence, procedure quality, and conservative decision-making. Additionally, personnel felt that they were able to trust all levels of site management.
Despite the increased efforts, there were still some challenges with translating the safety culture lessons into repeatable, sustainable safety culture behaviors on a consistent basis. The inspectors determined that some station personnel that were new to working at a nuclear site still had difficulty understanding nuclear safety culture. However, the sites senior management were looking at methods on how to communicate the sites expectations and ensuring that the site personnel are all operating with a common understanding and goal. Station personnel did articulate some site challenges during the individual interviews. Site personnel at all levels indicated a potential for some resource challenges in the future as Kewaunee Solutions proceeds with more resource intensive parts of the decommissioning project, but staff stated how the site was aware of this concern and was actively working to address it. Some staff also perceived that supervisors and technical staff were not held to the same standard of accountability as tradecraft employees. Nearly all personnel interviewed stated that they felt free to raise nuclear safety concerns through many avenues, including any level of management, the corrective action program, the Employee Concerns Program, and the NRC.
1.3 Conclusions Issues were identified by the licensee at appropriate thresholds and entered into the CAP. Issues were screened and prioritized commensurate with safety significance.
Licensee evaluations determined the significance of issues and included appropriate remedial corrective actions. Individuals at Kewaunee are comfortable with raising safety concerns. Kewaunee had recognized a few areas to strengthen its safety culture and are actively working in the areas.
2.0 Decommissioning Performance and Status Review at Permanently Shut down Reactors (IP 71801)
2.1 Inspection Scope The purpose of this portion of the inspection was to evaluate the status of decommissioning and to verify the decommissioning activities are in accordance with regulatory and license requirements.
2.2 Observations and Findings The inspectors noted that the licensee was currently in the process of preparing for significant radiological work in the containment building to start in CY2026. The inspectors discussed the program surrounding the waste handling building and supporting access points to limit the spread of radiological contamination while packaging potentially radiologically contaminated waste.
The inspectors walked down the industrial and radiological controlled areas and found operations in those areas were being performed adequately to ensure the physical and radiological safety of workers. The inspectors interviewed numerous staff and found that their knowledge was adequate to ensure a safe working environment.
2.3 Conclusions The inspectors determined that decommissioning activities were in accordance with the regulations and license requirements.
3.0 Occupational Radiation Exposure at Permanently Shut down Reactors (IP 83750)
3.1 Inspection Scope The purpose of this portion of the inspection was to evaluate the effectiveness of the licensees occupational radiation safety program to adequately protect worker health and safety from exposure to radiation or radioactive material.
3.2 Observations and Findings The licensee removed and replaced the sections of high dose-rated pipes and replaced with new pipes to prepare cavity drain piping for cavity cleaning and to accept water. The inspectors reviewed the cavity drain line survey, the lapel air sampling, the RWP, the pre-job dose assessments, and the workers exposures.
The workers doses were well below the regulatory limit and within the range of pre-job dose assessments.
The inspectors also interviewed individuals associated with the radiation monitoring program and found that there was adequate knowledge to implement licensee procedures and maintain occupational exposures ALARA. The inspectors walked down Radiologically Controlled Areas and found areas properly posted and controlled. The inspectors also observed selected instrumentation source checks and found all instruments were functioning adequately.
3.3 Conclusions Adequate protection of worker health and safety from exposure to radiation and radioactive material was provided. Decommissioning activities were executed in general alignment with planning documents and as provided in RWPs and ALARA reviews. Radiation surveys were performed adequately to identify the hazards present.
4.0 Remedial and Final Surveys at Permanently Shut down Reactors (IP 83801)
4.1 Inspection Scope The purpose of this portion of the inspection was to evaluate the effectiveness of the licensees remedial and final survey program to adequately protect the public health and safety from exposure to radiation or radioactive material.
4.2 Observations and Findings The inspectors reviewed the radiological analysis of samples collected from the sumps of the Auxiliary Building to determine the ratios of Radionuclides of Concern (ROC) in the drain line and discussed the drain line measurements with the licensee personnel to ensure that the residual contamination of the drain line will be properly characterized. The inspectors reviewed the core sampling results of concrete surfaces of Auxiliary and Containment Buildings to ensure that the characterizations were properly conducted. The inspectors also interviewed the licensee personnel about the calibration of core sample counting geometry using LABSOCS calibration software from the on-site laboratory to ensure that ROC in the building surfaces were properly quantified.
The inspectors reviewed the unconditional release surveys of the Turbine Building.
The surveys included the surfaces of the floor and wall. The smears of alpha/beta and the direct measurement of beta were indistinguishable from the background.
During the inspection, the inspectors also observed the worker conducting the survey of the components such as pipe removed from the building. The inspectors determined that no elevated readings were identified.
The inspectors reviewed the licensees Final Status Survey implementation for Survey Area 8101. The inspectors noted that the radiological surveys were performed in accordance with the procedure and good health physics practices.
4.3 Conclusions Adequate protection of the public health and safety from exposure to radiation and radioactive material was provided.
5.0 Radioactive Waste Treatment and Effluent Environmental Monitoring (IP 84750)
5.1 Inspection Scope The purpose of this portion of the inspection was to evaluate the effectiveness of the licensees liquid and gaseous effluent sampling program to quantify radioactive effluent releases and to verify that the radiological environmental monitoring program and groundwater protection initiative were effectively implemented.
5.2 Observations and Findings The inspectors reviewed the radiological controls for the Weld Shop prior to demolition. The inspectors reviewed the survey results of items and structures of the building. The smears and direct measurements of beta/gamma were not distinguishable from the background readings. The inspectors reviewed air sampling analytical results during the demolition and determined that no licensed materials were identified.
The inspectors reviewed the licensees wastewater treatment and discharge procedures and implementation. At the time of the inspection, the licensee had adequate procedures and implementation to determine discharges were in accordance with applicable release criteria.
5.3 Conclusions The liquid and gaseous effluent sampling program was effective at quantifying radioactive effluent releases and was implemented in accordance with applicable procedures.
6.0 Material Control and Accounting (IP 85103)
6.1 Inspection Scope The inspectors reviewed the licensees Material Control and Accounting (MC&A)
program to determine whether the licensee implemented and maintained an adequate and effective program to control and account for the SNM in its possession. The inspectors review included an assessment of the licensees ability to detect loss or theft of SNM in a timely manner.
6.2 Observations and Findings The inspectors reviewed applicable procedures and inventory records to determine whether MC&A activities involving both fuel and non-fuel SNM were implemented appropriately. The inspectors also conducted independent observations to verify spent nuclear material locations were in accordance with applicable records.
6.3 Conclusions The licensees program was intended to control and account for all SNM on-site, as well as detect any loss or unauthorized diversion of SNM in a timely manner. The licensee had implemented an adequate program to inventory and control the SNM on-site. Overall, the licensee had implemented the MC&A program in accordance with the regulations.
7.0 Exit Meeting The inspectors presented the results of the inspection to Ronald Worster and other members of the Kewaunee Solutions and Decommissioning staff at an exit meeting on July 24, 2025. The licensee acknowledged the results presented and did not identify any of the information discussed as proprietary.
ATTACHMENT: SUPPLEMENTAL INFORMATION
SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED General Manager/Project Director B. McMahon Decommissioning Plant Manager J. Lynch Regulatory Affairs Director D. Shannon RP Technical Manager D. Peterson Radiation Protection Manager T. Schneider Licensing Manager INSPECTION PROCEDURES USED IP 40801 Problem Identification and Resolution at PSRs IP 71801 Decommissioning Performance and Status Review at Permanently Shut down Reactors IP 83750 Occupational Radiation Exposure at Permanently Shut down Reactors IP 83801 Remedial and Final Surveys at Permanently Shut down Reactors IP 84750 Radioactive Waste Treatment and Effluent Environmental Monitoring IP 85103 Material Control and Accounting ITEMS OPENED, CLOSED, DISCUSSED Opened Type Summary None Closed Type Summary None Discussed Type Summary None
PARTIAL LIST OF DOCUMENTS REVIEWED The following is a partial list of documents reviewed during the inspection. Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather that selected sections of portions of the documents were evaluated as part of the overall inspection effort. Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.
- RP-KW-001-016 Large Component Removal Activities
Permit 25-009 Containment B - Steam Generator Cubicle RCP Casing
Procedure No. KS-IS-PR-302 Rev. 1 Kewaunee Solutions SNM Tamper Indicating Devices
Procedure No. KS-IS-PR-302 Rev. 2 Kewaunee Solutions SNM Tamper Indicating Devices
Procedure No. KS-RP5-PR-003 Rev. 0 Kewaunee Solutions Radiological Air Sampling and Analysis
Procedure No. RP-KW-223 Rev 7 Contamination Surveys
Procedure No. RP-KW-222 Rev. 1 Radiation Surveys
Procedure No. RP-KW-109 Rev. 1 Radiological Survey Program
Procedure No. RP-KW-106 Rev. 1 Radiological Work Control Program
FSS Sample Plan Sheet: Survey Area No. 8000; Survey Unit No.: 8101
Procedure No. RP-KW-275 Rev.3 Radiological Risk Assessment Process
Procedure No. NF-KW-REP-022 Rev. 0 Special Nuclear Materials Control
Procedure No. KS-IS-PR-022 Rev. 2 Kewaunee Solutions Special Nuclear Materials Control - Physical Inventory
Procedure No. KS-AD-PR-001 Rev. 9 Kewaunee Solutions Procedure Control
Procedure No. AD-KW-102 Rev. 3 Procedure Use and Adherence
Procedure No. OP-KW-NOP-RM-001 Rev. 14 Process Radiation Monitoring System
Procedure No. KS-OP-PR-003 Rev. 1 Kewaunee Solutions Wastewater Processing and Discharge
Procedure No. OP-KW-NOP-FP-001 Rev. 21 Fire Protection System
CR No. 2575; NRC Information Notice 2023-04 Operating Experience; 09/18/2023
CR No. 2671; Radioactive Sources Not Controlled as Required; 12/19/2023
CR No. 2674; Monthly Fire Extinguisher Inspection Deficiencies; 12/21/2023
CR No. 2737; NRC Information Notice 2024-01, Minimization and Control of Contamination Involving Discrete Radioactive Particles at Decommissioning Facilities; 02/22/2024
CR-2024-0327; Unanticipated Dose Rate Alarm; 04/18/2024
CR-2024-0478; Individual Received Electronic Dosimeter Dose Alarm; 06/04/2024
CR-2024-0696; Bravo Cubicle Incipient Fire; 08/07/2024
CR-2024-0793; Vehicle Alarmed Exit Radiation Monitor; 08/29/2024
CR-2025-0066; Lost TLD; 01/21/2025
CR-2025-0067; Incipient Fire Containment Building; 01/21/2025
ES-AD-PR-008; Condition Reports; Revision 20
ES-AD-PR-011; Operating Experience and Lessons Learned Program; Revision 5
- ES-AD-PR-012; Cause Analysis; Revision 7
KS-QA-AUD-2023-0005; 2023 Kewaunee Training, Qualification, Measuring and Test Equipment, Corrective Action, Independent Review, ISFSI Technical Specifications and Fire Protection; 10/17/2023
KS-QA-PG-001; Kewaunee Solutions Decommissioning Quality Assurance Program (DQAP); Revision 1
Kewaunee Activation Analysis and Component Characterization Report 21-043-RE-277 Rev. 1 dated February 2024 LIST OF ACRONYMS USED ADAMS Agencywide Document Access and Management System ALARA As Low As is Reasonably Achievable CAP Corrective Action Program CFR Code of Federal Regulations CY Calendar Year KPS Kewaunee Power Station DRSS Division of Radiological Safety and Security IP Inspection Procedure ISFSI Independent Spent Fire Storage Installation MC&A Material Control and Accounting NRC Nuclear Regulatory Commission PSR Permanently Shut down Reactor ROC Radionuclides of Concern RP Radiation Protection RWP Radiation Work Permit SNM Special Nuclear Material