IR 05000255/2024003
| ML24317A199 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/14/2024 |
| From: | Dave Hills NRC/RGN-III |
| To: | Mlynarek M Holtec Decommissioning International |
| References | |
| IR 2023001, IR 2024003 | |
| Download: ML24317A199 (1) | |
Text
SUBJECT:
PALISADES NUCLEAR PLANT - NRC INSPECTION REPORT NO. 05000255/2024003; 07200007/2023001
Dear Mike Mlynarek:
On September 30, 2024,the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Palisades Nuclear Plant. On October 8, 2024, the NRC inspectors discussed the results of this inspection with Mike Mlynarek, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
During the inspection, the NRC inspectors reviewed the following aspects of onsite activities:
safety reviews, design changes and modifications; decommissioning emergency preparedness scenario review and exercise evaluation; decommissioning emergency preparedness program evaluation; occupational radiation exposure; radioactive waste treatment and effluent controls; and waste management and transportation. The inspection consisted of an examination of activities at the site as they relate to safety and compliance with the Commissions rules and regulations.
No violations of more than minor safety significance were identified during this inspection.
November 14, 2024 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;72-007 License No: DPR-20
Enclosure:
IR Nos. 05000255/2024003 07200007/2023001
REGION III==
Docket No:
50-255;72-007 License No:
DPR-20 Report No:
05000255/2024003 07200007/2023001 Licensee:
Holtec Decommissioning International, LLC Facility:
Palisades Nuclear Plant Location:
Covert, MI Inspection Dates:
July 1, 2024, to September 30, 2024 Inspectors:
Valerie Myers, Sr Health Physicist Mathew Learn, Team Leader Daniel Sargis, 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. 05000255/2024003; 07200007/2023001 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 violations of more than minor safety significance were identified.
Safety Reviews, Design Changes, and Modifications
The licensee performed adequate safety evaluations or screenings, completed design change evaluations, and properly assessed decommissioning impacts of various work activities as required by 10 CFR 50.59 and its safety review process.
Decommissioning Emergency Preparedness Scenario Review and Exercise Evaluation
The inspectors determined that the licensee adequately planned and conducted the biennial exercise to demonstrate that it could implement the emergency plan and effectively assess its performance to identify and correct weaknesses.
Decommissioning Emergency Preparedness Program Evaluation
The inspectors determined that the licensee adequately maintained the emergency preparedness program.
Occupational Radiation Exposure
Adequate protection of worker health and safety from exposure to radiation and radioactive material was provided. Activities were executed in general alignment with planning documents and as provided in the Radiation Work Permits (RWPs) and As Low As is Reasonably Achievable (ALARA) reviews. Radiation surveys were generally performed adequately to identify the hazards present.
Radioactive Waste Treatment, and Effluent and Environmental Monitoring
The liquid and gaseous effluent sampling program was effective at quantifying radioactive effluent releases and the Groundwater Protection Initiative (GPI) were implemented in accordance with applicable procedures.
Solid Radioactive Waste Management and Transportation of Radioactive Materials
The licensee effectively processed, handled, stored, and transported radioactive material.
Onsite Fabrication of Components and Construction of an Independent Spent Fuel Storage Installation
The inspectors determined that the Independent Spent Fuel Storage Installation (ISFSI)
pad was constructed in accordance with site specific requirements and that the pad was designed in accordance with the Certificate of Compliance (CoC). The construction did not have any adverse impact on onsite operations
Report Details The inspectors determined that the Independent Spent Fuel Storage Installation (ISFSI) pad was constructed in accordance with site specific requirements and that the pad was designed in accordance with the Certificate of Compliance (CoC). The construction did not have any adverse impact on onsite operations Summary of Facility Status The Palisades Nuclear Plant is a permanently shut-down and defueled power reactor. During this inspection period, the licensee did not conduct any major decommissioning activities as defined in 10 CFR 50.2. However, the licensee was performing restart related activities during this period.
1.0 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors (IP 37801)
1.1 Inspection Scope The purpose of this portion of the inspection was to verify that the licensees safety review process was in accordance with the requirements of 10 CFR 50.59, Changes, tests, and experiments such that license amendments were obtained when required.
1.2 Observations and Findings Modifications and safety reviews related the Primary Coolant System (PCS)
decontamination efforts were inspected utilizing IMC 2562 and are included in inspection report 05000255/2024012 under IP 71111.18, Plant Modifications. As review of the modifications under IMC 2562 addresses the same areas as IMC 2561, credit toward IMC 2561 inspection completion is being taken.
No findings of significance were identified.
1.3 Conclusions The licensee performed adequate safety evaluations or screenings, completed design change evaluations, and properly assessed decommissioning impacts of various work activities as required by 10 CFR 50.59 and its safety review process.
2.0 Decommissioning Emergency Preparedness Scenario Review and Exercise Evaluation (IP 82401)
2.1 Inspection Scope The purpose of this portion of the inspection was to evaluate the adequacy of the licensees conduct of the biennial exercise and its capability to assess performance to identify and correct weaknesses.
2.2 Observations and Findings The inspectors reviewed the exercise scenario to evaluate whether it included elements for accident detection and assessment, emergency classification, notification of onsite and offsite emergency responders, communications, radiological exposure control, and shift staffing.
The inspectors observed exercise performance from the main control room as well as in the field. The control room observations focused on assessing whether the licensee was capable of detecting events and subsequently classifying the events and making appropriate off-site notifications in accordance with the emergency plan. In addition, the control room observations focused on the licensees ability to adequately assess both on-site and off-site radiological impacts from the exercise event. Observations from the field included assessment of communication capabilities between the control room and field team, accident mitigation strategies, and worker protection.
In addition, the inspectors observed post-exercise critiques from both exercise participants and exercise evaluators to assess the licensees ability to self-identify weaknesses. The inspectors also reviewed the after-action report to assess the licensees ability to address identified weaknesses.
No findings were identified.
2.3 Conclusions The inspectors determined that the licensee adequately planned and conducted the biennial exercise to demonstrate that it could implement the emergency plan and effectively assess its performance to identify and correct weaknesses.
3.0 Decommissioning Emergency Preparedness Program Evaluation (IP 82501)
3.1 Inspection Scope The purpose of this portion of the inspection was to determine whether the licensees emergency preparedness program is maintained in a state of operational readiness and whether changes made to the licensees emergency preparedness program continue to meet requirements and have not negatively affected the licensees overall state of emergency preparedness.
3.2 Observations and Findings There were no actual events that cause the licensee to implement the E-plan. There were no licensee-initiated changes to the emergency plan since the NRC approved permanently defueled emergency plan issued under License Amendment Request 274 on December 27, 2023. The inspectors reviewed various criteria in emergency plan implementing procedures to assess program implementation. This included review of required drills, program audits, and maintenance of required equipment & kits stagged for use.
No findings were identified.
3.3 Conclusions The inspectors determined that the licensee adequately maintained the emergency preparedness program.
4.0 Occupational Radiation Exposure at Permanently Shutdown Reactors (IP 83750)
4.1 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.
4.2 Observations and Findings Radiologically risk significant work related to the PCS chemical decontamination activities were inspected this quarter utilizing IMC 2562 and are included in inspection report 05000255/2024012 under IP 71124.0, Radiological Hazard Assessment and Exposure Controls. As review of the occupational radiation safety program under IMC 2562 addresses the same areas as IMC 2561, credit toward IMC 2561 inspection completion is being taken.
One SLIV NCV was identified and is discussed in IR 05000255/2024012.
4.3 Conclusions Adequate protection of worker health and safety from exposure to radiation and radioactive material was provided. Activities were executed in general alignment with planning documents and as provided in RWPs and ALARA reviews. Radiation surveys were generally performed adequately to identify the hazards present.
5.0 Radioactive Waste Treatment, and Effluent and 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 Groundwater Protection Initiative (GPI) were effectively implemented.
5.2 Observations and Findings The inspectors performed walkdowns of liquid and gaseous effluent systems and radiation monitors and observed sampling and analysis of stack gaseous effluents. In addition, the inspectors reviewed calibration and function test records for the stack gaseous effluent monitor, liquid radwaste monitor, and service water monitor as well as calibration and operation of gamma spectroscopy units used to analyze effluent samples. The inspectors reviewed various liquid and gaseous discharge calculations and permits for previously completed releases. For review of the groundwater protection initiative, the inspectors reviewed the most recent groundwater assessment report and vendor analysis reports.
No findings were identified.
5.3 Conclusions The liquid and gaseous effluent sampling program was effective at quantifying radioactive effluent releases and the GPI were implemented in accordance with applicable procedures.
6.0 Solid Radioactive Waste Management and Transportation of Radioactive Materials (IP 86750)
6.1 Inspection Scope The purpose of this portion of the inspection was to evaluate the effectiveness of the licensees programs for processing, handling, storage, and transportation of radioactive material.
6.2 Observations and Findings The inspectors performed walkdowns of radwaste storage areas for labeling, posting, controls, container integrity, and security controls. These walkdowns included areas within the auxiliary building, east rad waste building, and control of resin from the PCS chemical decontamination evolution. The inspectors observed shipment preparation and security controls for spent resin from the PCS chemical decontamination activities and reviewed a completed resin shipment. In addition, the inspectors observed the preparation of several shipments of PCS chemical decontamination equipment being returned to the vendor.
No findings were identified.
6.3 Conclusions The licensee effectively processed, handled, stored, and transported radioactive material.
7.0 Onsite Fabrication of Components and Construction of an Independent Spent Fuel Storage Installation (ISFSI) (IP 60853)
7.1 Inspection Scope The purpose of this inspection was to review and assess whether the ISFSI Dry Storage System (DSS) components are fabricated/constructed in accordance with the Certificate of Compliance (CoC) and NRC requirements.
This inspection also evaluates whether the licensee is properly reviewing ISFSI construction activities for determination of no adverse impact on site operation.
7.2 Observations and Findings The licensee procured materials and services for the new pad construction in accordance with their quality assurance program and in accordance with the design standards for the new pad.
The inspectors, with the assistance of technical experts in headquarters, verified that the ISFSI pad design was adequate to support the static and dynamic loads of the stored DSSs. The inspectors determined that there would not be an adverse impact on the plant or other ISFSI components stored in the vicinity of the new pad.
The licensee performed site excavation, backfill, and compaction in accordance with site procedures and CoC requirements. The inspectors reviewed the rebar layout prior to concrete placement and identified multiple examples of rebar spacing that was out of tolerance from the design specifications. The out of tolerance conditions were minor in nature and would likely not have impacted the strength or capability of the pad. The licensee corrected the identified conditions before placing concrete.
The inspectors observed that the licensee performed required testing of the concrete for slump, water content, air content, and performed strength tests of the cured concrete.
The quality control standards for the tests were met in accordance with applicable codes and standards.
No findings were identified.
7.3 Conclusions The inspectors determined that the ISFSI pad was constructed in accordance with site specific requirements and that the pad was designed in accordance with the CoC. The construction did not have any adverse impact on onsite operations.
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 October 8, 2024.
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 K. Schultz, Sr. Project Manager K. Miller, Emergency Preparedness Manager G. Wright, Radiation Protection Manager INSPECTION PROCEDURES (IPs) USED IP 37801 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors IP 60853 Onsite Fabrication of Components and Construction of an Independent Spent Fuel Storage Installation IP 82401 Decommissioning Emergency Preparedness Scenario Review and Exercise Evaluation IP 82501 Decommissioning Emergency Preparedness Program Evaluation IP 83750 Occupational Radiation Exposure IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials ITEMS OPENED, CLOSED, AND DISCUSSED Opened Type Summary None 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.
- 2023-I-05; Emergency Preparedness Audit Report; 04/28/2024
- Post-Shutdown Emergency Plan; Revision 33
- Permanently Defueled Emergency Plan; Revision 35
- Permanently Defueled Emergency Action Level Technical Baises; Revision 9
- July 17, 2024 Exercise Scenario; Revision 0
- EN-EP-306; Drills and Exercises; Revision 12
- EN-EP-308; Emergency Planning Critiques; Revision 07
- EI-3; Communications and Notifications; Revision 39
- EI-6.9; Automated Dose Assessment Program; Revision 18
- EI-8; Onsite Radiological Monitoring; Revision 20
- EI-16.1; Maintenance of Emergency Equipment
- Branson South Haven Hospital Letter of Agreement; 03/29/2024
- Covert Fire Department Letter of Agreement; 03/27/2024
- Emergency Planning Drill Report for July 17, 2024; 08/06/2024
- Health Physics Drill Report; 11/08/2023
- On-Site Medical Drill Report; 12/22/2023
- WO 50084625; Emergency Kite Check List; 12/28/2023
- PAL-01074; NIOS Observations During Audit; 04/11/2023
- PAL-01434; OSC Radios Not Functioning; 10/12/2023
- WO 52992615; Radiation Noble Gas Effluent Monitor RIA-2326; 06/07/2023
- WO 50084293; Process Monitor Monthly Function Checks; 08/01/2024
- WO 50084354; Process Monitor Quarterly Function Checks; 07/18/2024
- WO 52984613; Gaseous Particulate Effluent Monitor RIA-2325 Calibration; 03/08/2023
- WO 88800007; Operators Daily/Weekly Items Permanently Defueled; 07/21/2024
- WO 50084555; Radwaste Discharge Monitor (RIA-1049) Calibration; 08/14/2024
- WG-071724B; Waste Gas Decay Tank Release Order; 07/20/2024
- LRW-090924; Liquid Rad Waste Batch Release Order; 09/10/2024
- WO 50084266; Stack Effluent Sampling and Calculation; 01/31/2024
- Updated Hydrogeological Investigation Report; 09/14/2023
- CH 6.21; Radioactive Liquid Release; Revision 19
- CH 6.25; Gaseous Tritium Effluent; Revision 5
- DWR-10; Stack Effluent Sampling and Calculations; Revision 73
- EN-CY-111; Radiological Groundwater Protection Program; Revision 12
- 2023 Annual Radioactive Effluent Release Report; 4/23/2024
- Offsite Dose Calculation Manual; Revision 35
- WI-RSD-R-008; Spent Resin Transfers to Resin Liners in Track Alley; Revision 25
- WI-RSD-R-013; Surface Contaminated Object Shipments; Revision 11
- WI-RSD-R-027; Storage of Radioactive Material; Revision 2
- EN-RW-1002; Radioactive Shipping Procedure; Revision 22
- 2024-RW-005; Bead Resin Liner #160L-24018 Shipping Package; 07/23/2024
- C-3063; ISFSI Pad Design; Revision 3
- Cert. No. 85437270; Certified Mill Test Report; 08/03/2023
- DWG-13774; Palisades General Arrangement Drawing; Revision 1
- EA-EAR-2000-0309-13; Soil-Structure Interaction Analysis; Revision 2
- EA-EC-7408-01, Re-Evaluation of ISFSI Foundation Pad for Revised Loads Due to 24PTH System, Revision 0
- EDCR-3226-(S)013; Plate Load Test Results; Revision 0
- FCR 32261015; Rebar Procedure Does Not Have Inspection Step for Clearance Between Rebar; 10/09/2023
- HI-2188552; Impact of Construction and Added Mass on Existing TN Modules and ISFSI Pads; Revision 2
- HI-2230165; Palisades Engineering Change Package - Canister Transfer Pit; Revision 0
- HI-2230166; Palisades Engineering Change Package - ISFSI Expansion; Revision 0
- HI-2230187; Construction Specification for Palisades ISFSI Expansion; Revision 0
- HI-2230606; Seismic Analysis of Stack-Up and Structural Evaluation of Mating Device and CTP; Revision 0
- HI-2230791; Soil-Structure Interaction and Structural Qualification of the ISFSI Pads; Revision 0
- Report CC-000026-01; Compressive Strength of Concrete Test; 11/15/2023
- RRTI-3226-0001; CTP and ISFSI Pad Structural Qualification; Revision 0 LIST OF ACRONYMS USED ADAMS Agencywide Document Access and Management System ALARA As Low As Is Reasonably Achievable CFR Code of Federal Regulations CoC Certificate of Compliance DRSS Division of Radiological Safety and Security DSS Dry Storage System GPI Groundwater Protection Initiative IP Inspection Procedure IR
Inspection Report
Independent Spent Fuel Storage Installation
NRC
U.S. Nuclear Regulatory Commission
Radiation Work Permit