IR 05000255/2023003
| ML23276B452 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/04/2023 |
| From: | Dave Hills NRC/RGN-III/DRSS |
| To: | Mlynarek M Holtec Decommissioning International |
| References | |
| IR 2023003 | |
| Download: ML23276B452 (1) | |
Text
SUBJECT:
NRC INSPECTION REPORT NO. 05000255/2023003(DRSS)-HOLTEC DECOMMISSIONING INTERNATIONAL, LLC, PALISADES NUCLEAR PLANT
Dear Mike Mlynarek:
On August 24, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed onsite inspection activities for July through August 2023, at the permanently shut-down Palisades Nuclear Plant in Covert, Michigan, with continuing in-office review through September 12, 2023.
The purpose of the inspection was to determine whether decommissioning activities were conducted safely and in accordance with NRC requirements. The enclosed report presents the results of this inspection, which were discussed with you and other members of your staff on September 12, 2023.
During the inspection period, the NRC inspectors reviewed the following aspects of onsite activities: decommissioning performance; occupational radiation exposure; radiological surveys; and radioactive waste treatment, effluent, and environmental monitoring. The inspection consisted of an examination of activities at the site as they relate to safety and compliance with the Commissions rules and regulations. Areas examined during the inspection are identified in the enclosed report. Within these areas, the inspection consisted of a selective examination of procedures and representative records, reviewing work activities, and interviews with personnel.
Based on the results of this inspection, the NRC did not identify any violations.
October 4, 2023 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 HP Branch Division of Radiological Safety and Security Docket No: 50-255 License No: DPR-20
Enclosure:
IR Nos. 05000255/2023003 (DRSS)
REGION III==
Docket No:
50- 0255 License No:
DPR-20 Report No:
05000255/ 2023003(DRSS)
Enterprise Identifier:
I-2023-003-0069 Licensee:
Holtec Decommissioning International, LLC Facility:
Palisades Nuclear Plant Location:
Covert, Michigan Dates:
July 10, 2023, to September 12, 2023 Inspectors:
V. Myers, Senior Health Physicist G. Flanders, Senior Health Physicist Approved by:
David E. Hills, Chief Decommissioning, Reactor, and ISFSI HP Branch Division of Radiological Safety and Security
EXECUTIVE SUMMARY Palisades Nuclear Plant NRC Inspection Report Nos. 05000255/2023003(DRSS)
The Palisades Nuclear Plant is permanently shut-down and defueled power reactor. This periodic safety inspection reviewed licensed activities associated with decommissioning performance; occupational radiation exposure; radiological surveys; and radioactive waste treatment, effluent, and environmental monitoring.
Decommissioning Performance and Status Review
The inspectors reviewed documentation related to the decommissioning trust fund and met with the plant staff to discuss if the funds were used in accordance with NRC requirements.
The inspectors identified one unresolved item involving decommissioning trust funds used to pay for non-decommissioning activities.
Occupational Radiation Exposure
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. Command and control of radiologically significant activities was executed in a manner that was safe and achieved the desired result.
Radioactive Waste Treatment, and Effluent and Environmental Monitoring
The effluent flow paths and environmental monitoring systems reviewed aligned with descriptions in the Offsite Dose Calculation Manual and were functional. The effluent monitors reviewed were functional, calibrated, and alarm set points conservatively set to meet regulatory requirements. Changes to the effluent and environmental monitoring program were consistent with regulatory requirements.
Report Details Summary of Plant Activities During this inspection period, the licensee continued activities associated with Period 2 of the Post Shutdown Decommissioning Activities Report (PSDAR). No major decommissioning activities occurred during the inspection period.
1.0 Decommissioning Performance and Status Review (IP 71801)
1.1 Inspection Scope The inspectors reviewed documents, and interviewed plant personnel to assess the licensees performance in the following areas:
Changes to the decommissioning schedule or costs were made consistent with the requirements in 10 CFR 50.82(a)(7).
The inspectors verified that when issues were identified, licensee personnel appropriately documented the issues in the Corrective Action Program (CAP).
1.2 Observations and Findings The inspectors reviewed documentation related to the use of the decommissioning trust fund (DTF). Specifically, there were seven instances totally just over $53,000 in which the licensee used decommissioning trust funds to pay for non-decommissioning activities. The licensee entered this matter into its corrective action program and repaid the money back to the DTF with interest. The licensee stated that the unauthorized reimbursements from the DTF were the result of inadvertent oversights and/or inattention to detail; that is, they were the result of human performance errors, not process-related or programmatic issues. As a result, the licensee instituted several process revisions addressing purchase order coding modifications and training to ensure such unauthorized reimbursements do not occur in the future. This is considered an unresolved item (URI 05000255/2023003-01) pending further NRC review to ascertain if a violation of NRC requirements occurred, and if so, the appropriate enforcement action.
1.3 Conclusions The inspectors identified one unresolved item involving decommissioning trust funds used to pay for non-decommissioning activities.
2.0 Occupational Radiation Exposure at Permanently Shutdown Reactors (IP 83750)
2.1 Inspection Scope The inspectors performed walkdowns, reviewed documents, and interviewed plant personnel to assess the licensees performance in the following areas:
Changes made to organization, personnel, facilities, instrumentation, equipment, and programs that impact occupational radiation protection;
Training and qualifications of members of the radiation protection organization;
Radiological hazards and worker protection in work activities;
Planning identified appropriate dose reduction techniques, defined reasonable dose goals, and radiation protection hold points;
Radiological controls, postings, and material conditions inside the radiological control area;
Planned special exposures;
External exposure dosimetry; Internal exposure dosimetry; Special dosimetric situations;
Engineering controls, respiratory protection program, and dose assessments;
Contamination monitoring including release of radioactive materials from controlled areas;
Accuracy and functionality of radiation monitoring instruments;
Area radiation monitors and continuous air monitors were appropriately positioned;
Temporary ventilation systems were correctly configured; and
The characterization of the radiation type and energies were appropriate to the surveys and work practices.
The inspectors verified that when issues were identified, licensee personnel appropriately documented the issues in the CAP.
2.2 Observations and Findings The inspectors performed walkdowns of the plant on August 22-23, 2023. There were no changes to the licensees organization that impacted the radiation protection program.
The inspectors found that adequate measures were established in the plant building to reasonably prevent the creation of airborne hazards; control the spread of contamination; and to reduce external dose. A review of selected radiological surveys did not identify any unusual radiological conditions. During tours of the radiation area and high radiation area, the inspectors observed that general housekeeping had been maintained, radiological postings and barriers were found to be in good condition and properly located, and all personnel were appropriately monitored through the inspection period.
No findings were identified.
2.3 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. Command and control of radiologically significant activities was executed in a manner that was safe and achieved the desired result.
3.0 Radioactive Waste Treatment, and Effluent and Environmental Monitoring (IP 84750)
3.1 Inspection Scope The inspectors performed walkdowns, reviewed documents, and interviewed plant personnel to assess the licensees performance in the following areas:
Changes made to the Offsite Dose Calculations Manual (ODCM) or liquid, gaseous, and solid radwaste system design and operation were within the licensing basis and regulations;
Effluent monitoring ventilation and discharge system configurations, flow paths, and operations were consistent with the licensing basis and procedures;
Effluent monitors were calibrated;
Radioactive liquid and gaseous waste discharge permits projected doses to members of the public that were based on representative samples in the discharge pathway and were within 10 CFR Part 50, Appendix I, and Technical Specification limits;
The annual effluent release report was submitted as required, and any anomalous results, unexpected trends, or abnormal releases were identified and entered into the Corrective Action Program;
Environmental monitoring equipment was properly located, calibrated and maintained, and environmental samples were adequately collected;
Whether the Groundwater Protection Initiative program was implemented as intended;
Whether potential leakage or spills were appropriately added to records as required by 10 CFR 50.75(g);
The licensees annual radiological environmental monitoring report was submitted as required, and any anomalous results, unexpected trends, or abnormal environmental impacts were identified and entered into the Corrective Action Program;
Meteorological instruments were operable, calibrated, and maintained in accordance with the Final Safety Analysis Report;
Whether the licensees vendor laboratory analyzed environmental samples under an approved quality control program and the inter-laboratory comparison program was adequate; and
Changes made to the environmental program.
The inspectors verified that when issues were identified, licensee personnel appropriately documented the issues in the CAP.
3.2 Observations and Findings There were no changes with respect to the monitoring of plant liquid or gaseous effluent pathways during this inspection period. The inspectors observed the licensee performing weekly air samples, weekly RETS water analysis, RIA-5211 turbine building sump Rad monitor Calibration, and monthly Palisades Park Commercial Well sampling. The inspectors noted during a review of the 2022 Annual Radioactive Effluent Release and Waste Disposal and Radiological Environmental Operating reports that no anomalous results, unexpected trends, or abnormal releases were identified in association with the plant activities. Since the last inspection, there were no spills or leakage associated with
plant activities requiring records to be maintained in accordance with 10 CFR 50.75(g).
The inspectors performed walkdowns of the plant on July 10-13, 2023, and observed that the effluent monitors were calibrated and consistent with the licensees procedures and ODCM.
No findings were identified.
3.3 Conclusions The effluent and environmental monitoring program elements reviewed aligned with descriptions in the Offsite Dose Calculation Manual. The effluent monitors reviewed were calibrated and alarm set points appropriately set to meet regulatory requirements.
Changes to the effluent and environmental monitoring program were consistent with regulatory requirements.
9.0 Exit Meeting The inspectors presented the results of the inspection to Mike Mlynarek and other members of the Palisades Nuclear Plant staff at an exit meeting on September 12, 2023.
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 M. Mlynarek, Site Vice President M. Schultheis, Regulatory Assurance Manager M. Bailey, Operations Director G. Wright, Radiation Protection Manager J. Miksa, Regulatory Assurance Engineer B. Noval, Fleet Licensing Director S. Summers, Security Manager J. Borah, Maintenance Manager J. Jerz, Engineering Manager INSPECTION PROCEDURES (IPs) USED IP 71801 Decommissioning Performance and Status Reviews at Permanently Shutdown Plants IP 83750 Occupational Radiation Exposure IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring ITEMS OPENED, CLOSED, AND DISCUSSED Opened Type Summary 05000255/2023003-01 URI Review of Decommissioning Trust Fund Withdrawals Closed 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.
- 2022 Prospective Evaluation for Palisades Station; 08/09/2023
- COP-27; 06/15/2022
- DWC-11D; 06/12/2022
- RO-20 1445; 06/28/2023
- RO-20 1733; 05/08/2023
- RO-20 1740; 06/28/2023
- L177 COFC 1297; 05/26/2023
- QA-14-15-2021-PLP-1; 09/20-11/02/2021
- WO-52999877-01; 02/27/2023
- PAL-01248; 07/13/2023
- PAL-00697; 02/15/2023
- 2022 Radiological Environmental Operating Report; 04/18/2023
- 2022 Annual Radioactive Effluent Release and Waste Disposal Reports; 04/19/2023
- CH 11.6; Radiation Protection; Revision 36
- CH 12.2; Training; Revision 36
- CH 9.0; Auxiliary System; Revision 36
- CH 9.9; Sampling System; Revision 36
- RWP 2023-0209; 01/01/2023
- RWP 2023-0001; 01/01/2023
- RWP 2023-0007; 03/21/2023
- CH 6.21; Radioactive Liquid Release; Revision 18
- CH 6.23; Waste Gas Decay Tank Release; Revision 21
- CH 6.25; Gaseous Tritium Effluent; Revision 5
- COP-17; Radwaste System Chemistry; Revision 35
- COP-33; Plant Water Storage and Transfer Systems Chemistry; Revision 37
- CH 6.25-3; Release Order for LRW-053123; 06/07/2023
- CH 6.25-3; Release Order for WG-091622; 09/16/2022
- EN-CY-102-01; Quality Control for Analytical Laboratory Interlab and Intralab Cross-Check Programs; Revision 2
- LADTAP and GASPAR Calculation; 06/01/2023
- DSP-WC-DC-100; MET Tower Bi-Annual Instrument Calibration; 11/14/2022
- WO 50084266; DWR-10 Stack Effluent Sampling and Calculation; 06/21/2023
- WO 52886258; RR-91-Waste Gas Dis Mon RIA-1113 Cal; 12/09/2020
- WO PAL-00699; RIA-1113; Waste Gas Discharge Monitor OOS; 08/25/2022
- WO 52971441; RIA-1049 Calibration; 11/03/2022
- WO 50084468; FIC-1051/FT-1051 Calibration; 08/18/2022
- WO 52893473; FIC-1050/FT-1050 Calibration; 01/22/2021
- WO 50084205; Test FIS-2326 on RIA-1323; 04/25/2023
- Gamma Isotopic Results for MR-36 Weekly Composite; 07/10/2023
- Offsite Dose Calculation Manual Change Review for Revision 34; 04/10/2023
- Radiochemistry Cross Checks Results, 2nd Quarter 2023; 06/12/2023
- Intralaboratory Analyses Results for 2022; 01/10/2023
- Teledine Brown Engineering 4th Quarter 2022 Quality Assurance Report; 01/26/2023
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 DRSS Division of Radiological Safety and Security DTF Decommissioning Trust Fund IP Inspection Procedure IR
Inspection Report
Independent Spent Fuel Storage Installation
NRC
U.S. Nuclear Regulatory Commission
Offsite Dose Calculation Manual
Post Shutdown Activities Report
Radiation Protection
Radiation Work Permit
Radiological Effluent Technical Specifications
SAFSTOR
Safe Storage
TS
Technical Specification
Updated Final Safety Analysis Report
Unresolved Item