ML23058A253
| ML23058A253 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 03/22/2023 |
| From: | Anthony Dimitriadis Decommissioning, ISFSI, and Reactor Health Physics Branch |
| To: | Reid B ADP CR3 |
| References | |
| IR 2022003 | |
| Download: ML23058A253 (1) | |
See also: IR 05000302/2022003
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD, SUITE 102
KING OF PRUSSIA, PA 19406-1415
March 22, 2023
Billy Reid, Jr.
Site Vice President
2760 South Falkenburg Rd.
Riverview, FL 33578
SUBJECT:
ACCELERATED DECOMMISSIONING PARTNERS (ADP) CR3, LLC, CRYSTAL
RIVER UNIT 3 - NRC INSPECTION REPORT NO. 05000302/2022003
Dear Billy Reid:
On December 31, 2022, 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 (CR3). 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 John Jernigan, Decontamination & Decommissioning Licensing Manager, and
other members of your staff on March 13, 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).
B. Reid
2
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 05000302/2022003
w/Attachment
cc w/encl:
Distribution via ListServ
Anthony M.
Dimitriadis
Digitally signed by
Anthony M. Dimitriadis
Date: 2023.03.22
13:44:56 -04'00'
B. Reid
3
SUBJECT:
ACCELERATED DECOMMISSIONING PARTNERS (ADP) CR3, LLC,
CRYSTAL RIVER UNIT 3, NRC INSPECTION REPORT NO.
05000302/2022003 DATED MARCH 22, 2023
Distribution:
BWelling, DRSS
MRalph, DRSS
ADimitriadis, DRSS
SVeunephachan, DRSS
JParrott, DUWP
BWatson, DUWP
Document Name: https://usnrc.sharepoint.com/teams/Region-I-Decommissioning-Branch/Inspection
Reports/Inspection Reports - Final/3Q 4Q Crystal River Final Veunephachan.docx
SUNSI Review Complete:
After declaring this document An Official Agency Record it will be released to the Public.
ADAMS ACCESSION NO. ML23058A253
OFFICE
DRSS/RI
DRSS/RI
NAME
SVeunephachan/sv
ADimitriadis/ad
DATE
02/24/2023
03/22/2023
OFFICIAL RECORD COPY
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
INSPECTION REPORT
Report No.
Docket No.
05000302
License No.
Licensee:
Accelerated Decommissioning Partners CR3, LLC (ADP)
Facility:
Crystal River Unit 3 (CR3)
Location:
Crystal River, FL
Inspection Dates:
July 1 - December 31, 2022
Inspectors:
Storm Veunephachan, Health Physicist
Decommissioning, ISFSI, and Reactor Health Physics Branch
Division of Radiological Safety and Security
Jack D. Parrott, Senior Project Manager
Reactor Decommissioning Branch
Division of Decommissioning, Uranium Recovery
and Waste Programs
Office of Nuclear Material Safety and Safeguards
Approved By:
Anthony Dimitriadis, Chief
Decommissioning, ISFSI, and Reactor Health Physics Branch
Division of Radiological Safety and Security
2
EXECUTIVE SUMMARY
Accelerated Decommissioning Partners CR3, LLC (ADP)
Crystal River Unit 3
NRC Inspection Report No. 05000302/2022003
An announced decommissioning inspection was completed on December 31, 2022, 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 NRC's 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.
3
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 CR3 and the general
license for the CR3 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.
CR3 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 (IPs) 37801, 40801, 64704, 71801, 83750, 83801, 84750, and 86750
a. Inspection Scope
The inspectors performed on-site decommissioning inspections on September 12-14,
October 17-20, and November 14-17, supplemented by in-office reviews of
information supplied by ADP 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 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 interviewed the CAP manager to determine if a
sufficiently low threshold for problem identification existed, if follow-up evaluations
were of sufficient quality, and if the site assigned timely and appropriate prioritization
for issue resolution commensurate with the significance of the issue. The inspectors
also followed up on the action plan of a February 2022 Safety Conscious Work
Environment (SCWE) survey. The inspectors also reviewed ADPs Quality Assurance
Program Manual (QAPM) and interviewed the Quality Assurance (QA) manager.
The inspectors conducted plant walk-downs to assess field conditions and
decommissioning activities by evaluating the material condition of structures, systems,
and components, housekeeping, system configurations, and worker level of knowledge
or procedure use and adherence. These walk-downs included the reactor, auxiliary, and
4
turbine buildings. The inspectors observed select pre-job briefings and various work
activities in the turbine, auxiliary, and reactor buildings. The inspectors also observed
select management meetings, including a site leadership meeting and various morning
status meetings to assess the licensees status, progress and changes that could
potentially impact decommissioning.
The inspectors reviewed activities and documentation associated with radioactive
effluent control and the site radiological environmental monitoring program (REMP) to
assess the effectiveness of site radiological programs. The inspectors reviewed any
changes made to the Offsite Dose Calculation Manual (ODCM), Process Control
Program, and radioactive waste system design and operation. The inspectors reviewed
radioactive gaseous and liquid effluent release permits, licensee audits, 2022
groundwater monitoring reports and reviewed procedures associated with entering
events into the records system file as required by 10 CFR 50.75(g). The inspectors
interviewed staff and observed the liquid effluent treatment system by conducting site
walkdowns of the associated treatment system.
The inspectors observed a selection of environmental monitoring stations to evaluate
their location, placement, and material condition. The inspectors also observed several
media change-out activities (e.g., air sampling stations) to determine if appropriate
procedures were implemented effectively.
The inspectors observed activities, reviewed documentation, and interviewed personnel
associated with occupational radiation exposure to evaluate the licensees protection of
worker health and safety. The inspectors conducted several site walk-downs, including
radiologically controlled areas, to examine and assess radiological postings, airborne
and contamination controls, and locked high radiation doors and gates. The inspectors
observed dosimetry storage and interviewed staff to determine if staff had followed
appropriate site procedures and if staff had the appropriate knowledge and training.
The inspectors reviewed activities and documentation associated with the possession,
processing, storage, and shipment of licensed radioactive material. The inspectors also
reviewed work packages for select recent shipments of radioactive waste, interviewed
one of the site shippers, and toured radioactive waste handling and storage areas. The
inspectors performed observations of cutting operations of the reactor vessel internals to
determine if appropriate radiation protection practices had been applied and if the work had
been conducted in accordance with site procedures. The inspectors observed a radioactive
waste shipment to determine if associated procedures were implemented.
The inspectors evaluated the licensees methods and results for the radiological survey
of a potential residually contaminated land area being evaluated for release as part of the
decommissioning of the ADP CR3 site and facility. The inspection was supplemented
by in-office reviews of information supplied by ADP CR3 and periodic phone calls. The
inspection consisted of observations by the inspectors, interviews with site personnel, a
review of procedures and records, a walkdown of the survey area, and tour of the onsite
laboratory and facilities for the processing and storage of soil samples.
The inspectors reviewed the licensees implementing procedures, radiological
measurements, decommissioning surveys, and documentation of decommissioning
5
surveys. In addition, through the support of NRC contractor Oak Ridge Institute for
Science and Education (ORISE), the inspection also included confirmatory surveys of
the east settling pond area.
The east settling pond was one of the first areas to be surveyed under the ADP CR3 Final
Status Survey (FSS) procedures. NRC inspections of the licensees implementation of
these procedures will serve as a baseline to determine confidence in the implementation
of the sites FSS process while reviewing the LTP, and if the sites characterization
surveys had accurately determined the radiological classification of areas of the site.
The inspectors reviewed the licensees plans for implementing FSSs, the procedure for
isolating and controlling areas for FSSs, the plans for characterizing the settling ponds,
the historical site assessment (HSA), the training and qualification requirements for staff
that plan, review, and implement FSSs, and condition reports related to FSSs.
b. Observations and Findings
The inspectors determined that issues had been identified, entered into the CAP,
and evaluated commensurate with their safety significance through document
reviews. The inspectors verified that audits and self-assessments were performed by
qualified individuals, and management reviewed the audits and associated corrective
actions.
The inspectors continued an increased focus on the sites SCWE. The inspectors
continued review of the site response to a SCWE survey conducted in February
2022, which identified several weaknesses, including in the areas of respectful work
environment and workplace safety as well as lack of confidence that management
would appropriately resolve issues, and lack of confidence of the ability to stop work
without fear of retaliation. The inspectors interviewed ADP personnel to continue
follow-up actions associated with the SCWE survey results.
The inspectors noted that during this inspection period, the site continued
decommissioning and dismantlement activities in the auxiliary and turbine
buildings, continued segmentation of the reactor vessel internals, and prepared for
Greater-Than-Class-C (GTCC) waste transfer to radioactive waste canisters. The
inspectors noted that for the areas of the plant toured, the material condition and
housekeeping was adequate. The inspectors noted through plant tours, document
reviews, and observations of activities that ADP conducted activities in accordance
with the regulatory requirements.
The inspectors verified that radioactive effluent sampling and analysis requirements
were satisfied. The inspectors verified that the radiological environmental monitoring
program was consistent with technical specifications (TS) and the ODCM. The
inspectors also verified ADPs continued implementation of their groundwater
monitoring program.
The inspectors verified that the radiological respiratory protection and contamination
control programs had been properly implemented. The inspectors observed workers
donning and doffing respirators and personal protective equipment (PPE) and did not
identify any issues of concern. Additionally, the inspectors verified that radiation work
6
permits and As Low As Reasonably Achievable (ALARA) plans as implemented were
effective in limiting worker exposure, and occupational dose was appropriate for the
scope of the radiological activities performed. The inspectors determined that
Radiation Protection (RP) staff effectively controlled work activities, used appropriate
instruments for the surveys, and survey records were clear and complete. The
inspectors noted that the qualifications reviewed for selected staff met the
requirements in the site licensing basis.
The inspectors verified solid radioactive waste was adequately stored and monitored,
radioactive waste shipping paperwork was properly completed, and that ADP
personnel were knowledgeable of their duties and responsibilities. The inspectors
observed a resin liner lift from the reactor building and observed the packaging and
shipment of the liner as radioactive waste for disposal. The inspectors determined
radioactive waste shipped for disposal at land disposal facilities was properly
classified, described, packaged, marked, and labeled, and was in proper condition
for transportation.
The inspectors observed segmentation activities of reactor vessel internals, including
a core support assembly cut and resin liner lift, and interviewed staff performing the
operations. The inspectors reviewed and performed walk downs of the water filtration
system and cutting media collection system and noted appropriate radiological
controls were in place for current conditions. The inspectors determined that
activities had been performed in accordance with site procedures and appropriate
radiation protection practices had been employed.
The inspectors determined that the development, review, and approval of the survey
plan for the east settling pond adequately followed the procedures developed for
FSSs and verified the adequacy of the processing and archiving of the soil samples
taken from the east settling pond. The licensee staff that reviewed and implemented
the FSS was adequately trained and qualified for the implementation of the FSS.
Review of the HSA indicated that the radiological classification of the east settling
pond area as a Class 3 area (i.e., and area with little or no potential for small areas
of elevated activity and the presumption that if residual radioactivity is present,
its concentration will not exceed a small fraction of the acceptance criteria) was
adequate. The inspectors also found that the east pond area had been adequately
isolated and controlled since completion of the FSS of that area.
c. Conclusions
No violations of more than minor safety significance were identified.
3.0
Exit Meeting Summary
On March 13, 2023, the inspectors presented the inspection results to John
Jernigan, Decontamination and Decommissioning Licensing Manager, and other
members of the CR3 staff. No proprietary information was retained by the inspectors
or documented in this report.
7
ATTACHMENT: SUPPLEMENTAL INFORMATION
8
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
B. Reid, Site Vice President
B. Akins, Radiation Protection Manager
C. Burtoff, RP Engineer
J. Jernigan, Decommissioning Licensing Manager
G. McCallum, D&D Site Manager
C. Gavin, CAP Manager
L. Reader, RP Specialist
J. Bourassa, QA Manager
H. Van Sicklen, ISFSI Licensing Manager
L. McDougal, ORANO Project Manager
M. Sirochman, Operations Field Work Supervisor
ITEMS OPEN, CLOSED, AND DISCUSSED
None
PARTIAL LIST OF DOCUMENTS REVIEWED
Audits
CMPR-CR3-2022 IMA Report
Procedures
CP-500, Special Actions and Reporting Requirements, Revision 20
CP-161, Radiological Environmental Monitoring Program, Revision 14
CP9000, Radiological Groundwater Protection, Revision 4
SP0731A, Building Ventilation Continuous Release, Revision 32
SP0736L, Liquid Releases to the Discharge Canal, Revision 18
Condition Reports
2022000105
2022000117
2022000120
2022000124
2022000127
2022000131
2022000135
2022000136
9
Miscellaneous
2021 Annual Radiological Environmental Operating Report
2021 Annual Radioactive Effluent Release Report
Process Control Program, Revision 10
Off-Site Dose Calculation Manual, Revision 42
OR-CR3-22-010, Waste Manifest Shipping Paper
L-2022-001, Liquid Permit Release
L-2022-002, Liquid Permit Release
L-2022-003, Liquid Permit Release
L-2022-004, Liquid Permit Release
10 CFR 50.75(g) File
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
CR3
Crystal River Unit 3
D&D
Decommissioning and Demolition
DECON
Decommissioning
Duke Energy/DEF
Duke Energy Florida, Inc.
Final Status Survey
Greater-Than-Class-C
HSA
Historical Site Assessment
IMC
Inspection Manual Chapter
IP
Inspection Procedure
IR
Inspection Report
Non-cited Violation
NRC
U.S. Nuclear Regulatory Commission
Off-Site Dose Calculation Manual
ORISE
Oak Ridge Institute for Science and Education
Personal Protective Equipment
Quality Assurance
Radiological Environmental Monitoring Program
Radiation Protection
SAFSTOR
Safe Storage
Safety Conscious Work Environment
TS
Technical Specifications