IR 05000302/2024001
| ML24261C022 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 09/23/2024 |
| From: | Anthony Dimitriadis Decommissioning, ISFSI, and Reactor Health Physics Branch |
| To: | Reid B ADP CR3 |
| References | |
| IR 2024001 | |
| Download: ML24261C022 (1) | |
Text
September 23, 2024
SUBJECT:
ACCELERATED DECOMMISSIONING PARTNERS (ADP) CR3, LLC, CRYSTAL RIVER UNIT 3 - NRC INSPECTION REPORT NO. 05000302/2024001
Dear Billy Reid:
On June 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection under Inspection Manual Chapter 2561, Decommissioning 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 August 15, 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 system (ADAMS), accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response, if any, 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 05000302/2024001
cc w/encl:
Distribution via ListServ ANTHONY DIMITRIADIS Digitally signed by ANTHONY DIMITRIADIS Date: 2024.09.23 14:24:21 -04'00'
EXECUTIVE SUMMARY
Accelerated Decommissioning Partners CR3, LLC (ADP)
Crystal River Unit 3 NRC Inspection Report No. 05000302/2024001
An announced decommissioning inspection was completed on June 30, 2024, 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 [Agency Documentation and Management System (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 number 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 (IPs) 37801, 40801, 64704, 71801, 83750, and 86750
a. Inspection Scope
The inspectors performed on-site decommissioning inspection activities on January 12 - 20, April 08 - 11 and June 17 - 21, 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 reviewed the Quality Assurance Program Manual (QAPM). In addition, the inspectors also reviewed the training for safety conscious work environment (SCWE).
The inspectors assessed the implementation of ADPs safety review process that includes 50.59 screenings and 50.59 evaluations. The inspectors also determined that during this inspection period, the site was appropriately staffed and trained in accordance with its charter.
The inspectors conducted plant walkdowns 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 walkdowns included the reactor building, auxiliary building, and waste loadout area. The inspectors observed select pre-job briefings and various work activities in the 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 evaluated ADPs Fire Protection Program (FPP) as it continues to change to ensure that 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, manual suppression systems and fire department connections to assess the material condition and determine if it was adequately maintained. The walkdowns also served to evaluate if Crystal River implemented its fire protection plan.
The inspectors reviewed calibration certificates and procedures associated with radiation instrumentation. This was performed to determine if Crystal River was properly calibrating and source checking radiation detectors. Inspectors also observed source checking and calibration of various detector instrumentation to determine if they were functioning as required for monitoring airborne radioactivity and mitigating the spread of contamination outside of the radiological control area.
The inspectors observed activities, reviewed documentation, and interviewed personnel associated with occupational radiation exposure to evaluate the licensees protection of worker health and safety. This included reviewing Radiation Work Permits (RWP),
TEDE ALARA evaluations, program audit, and survey records. The inspectors conducted several site walkdowns, including radiologically controlled areas, to examine and assess radiological postings, airborne and contamination controls. 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 the respiratory protection program and respiratory protection training qualifications.
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 observed waste loadout from the reactor building until it was transported to the waste loadout area for rail shipment. The inspectors observed the radioactive waste shipment by barge of the segmented reactor vessel and reactor vessel closure head. The inspectors reviewed documentation such as procedures, work orders, and emergency response associated with barge shipments.
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 to follow up on the sites SCWE. The inspectors conducted interviews with the employee assistance program manager and reviewed follow up actions. The follow up actions included training for staff at various levels from laborer to upper management. Inspectors will continue to monitor SCWE on a routine basis in future inspections.
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 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 walkdowns, document reviews, and observations of activities, that ADP conducted activities in accordance with the regulatory requirements.
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 PPE and did not identify any issues of concern.
Additionally, the inspectors verified that RWPs and 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 RP (Radiation Protection) 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 that radiation instrumentation was properly calibrated and source checked. This was done by observing a calibration of a sample counter and observing source checks of instrumentation to ensure that they were functioning properly and could detect and prevent the spread of airborne or contamination outside of the radiological control area. Inspectors observed workers using a small article monitor and exiting through radiation detector portal monitors at the boundary of the radiological control area.
The inspectors verified that solid radioactive waste was adequately stored and monitored, that radioactive waste shipping paperwork was properly completed, and that ADP personnel were knowledgeable of their duties and responsibilities. The inspectors observed the barging process for the segmented reactor vessel and reactor vessel closure head. The reactor vessel was segmented into three separate pieces in which each piece was grouted and placed in the shipping package. Each package was then welded with nondestructive testing implemented to ensure the weld was adequate. The inspectors observed the storage of these waste containers before they were transported onto a barge. Inspectors were onsite to observe the process of transporting each shipment package from the storage location to the barge. The inspectors also observed controls implemented by RP and industrial safety personnel to ensure the packages were transported adequately. After the top, middle, and bottom packages were secured on the barge, the reactor vessel closure head was staged and secured. Inspectors were kept up to date on the location of the barge throughout its travel pathway. Inspectors observed the final radiation surveying before departure and reviewed the waste manifests for each package. The inspectors also reviewed the emergency procedures associated with a Type B shipment as warranted. The inspectors were notified once the barge reached its destination and was kept up to date on the location and movement of the packages to Waste Control Specialists (WCS) for final disposition.
The inspectors observed the continued dismantlement of the auxiliary building. The inspectors conducted walkdowns inside the auxiliary building to ensure airborne controls were implemented in accordance with site procedures. The inspectors observed the surveying of debris and loading out as radioactive waste. The inspectors also conducted walkdowns within the reactor building to observe continued dismantling activities. The inspectors observed large bore piping removal using plasma torching. The inspectors determined that the implementation of the fire protection program with the use of hot work permits and staging of airborne monitoring adequately followed procedures to limit the intake and spread of radioactive material.
c. Conclusions
No violations of more than minor safety significance were identified.
3.0
Exit Meeting Summary
On August 15, 2024, 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
- C. Burtoff, RP Engineer
- J. Jernigan, Decommissioning Site Manager
- L. McDougal, ORANO Project Manager
- T. Doruff, Work Control Manager
ITEMS OPEN, CLOSED, AND DISCUSSED
None
PARTIAL LIST OF DOCUMENTS REVIEWED
Audits
CR3-A-23-02, Radiological Protection Programs Audit
Procedures
FIR0100, Fire Extinguisher Inspections, Revision 3
OP9880, Decommissioning Fire Service System, Revision 6
WCP-1000, Integrated Work Control Program, Revision 5
REG10-2023-29
HPS-206, Dosimeter of Legal Record Quality Assurance, Revision 1
HPS-205, Prenatal Monitoring, Revision 0
NVLAP Certification of Accreditation
Condition Reports
24000006
24000007
24000005
24000039
24000023
24000018
24000019
24000021
Miscellaneous
OR-CR3-24-003
OR-CR3-24-002
OR-CR3-24-001
OR-CR3-24-004
HPSS0105, Estimating Airborne Radioactivity, Revision 4
CR3-CWP-ORANO-094, Reactor Vessel Transport Packages
CR3-CWP-ORANO-095, Barge Mooring & Ramp Installation
Radiation Work Permit 235, ALARA Plan
Health Physics Survey Record, 24-02-0057
Outgoing Shipment, 24-01-0171
Fire Hazards Analysis, Revision 21
HPP-500,Respiratory Protection Program, Revision 8
HPS0105, TEDE ALARA Evaluation
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
CR-3
Crystal River Unit 3
D&D
Decommissioning and Demolition
DECON
Decommissioning
Duke Energy/DEF
Duke Energy Florida, Inc.
IMC
Inspection Manual Chapter
IP
Inspection Procedure
IR
Inspection Report
Non-cited Violation
NRC
U.S. Nuclear Regulatory Commission
Quality Assurance
Quality Assurance Program Manual
Radiation Protection
SAFSTOR
Safe Storage
Safety Conscious Work Environment
Total Effect Dose Equivalent
TS
Technical Specifications
Waste Control Specialists