ML25027A457
| ML25027A457 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 02/05/2025 |
| From: | Jeremy Groom NRC/RGN-IV/DRSS |
| To: | Via T Omaha Public Power District |
| Shared Package | |
| ML25027A457 | List: |
| References | |
| EA-RIV-2024-0050 IR 2024004 | |
| Download: ML25027A457 (1) | |
See also: IR 05000285/2024004
Text
February 4, 2025
EA-RIV-2024-0050
Troy Via, Chief Operations Officer
and Vice President Utility Operations
Omaha Public Power District
Fort Calhoun Station
Mail Stop FC-2-4
9610 Power Lane
Blair, NE 68008
SUBJECT:
FORT CALHOUN STATION - NRC INSPECTION
REPORT 050-00285/2024-004
Dear Troy Via:
This letter refers to the U.S. Nuclear Regulatory Commission (NRC) decommissioning
inspection conducted on December 9-11, 2024, at the Fort Calhoun Station near Blair,
Nebraska. The purpose of the inspection was to examine activities conducted under your
license as they relate to public health and safety, the common defense and security, and
compliance with the Commissions rules and regulations, and with the conditions of your
license. Within these areas, the inspection consisted of selected examination of procedures and
representative records, observation of activities, and interviews with personnel. Specifically, the
inspectors reviewed your implementation of decommissioning activities; fire protection program;
and solid radioactive waste management and transportation of radioactive materials program.
The inspection results are documented in the enclosure to this letter. The NRC inspectors
discussed the preliminary results of the decommissioning inspection with members of your staff
on December 11, 2024, at the conclusion of the onsite portion of the inspection. A final exit
briefing was conducted with your staff via videoconference on January 22, 2025.
Based on the results of this inspection, one apparent violation was identified and is being
considered for escalated enforcement action in accordance with the NRC Enforcement Policy.
The Enforcement Policy is available on the NRCs website at http://www.nrc.gov/about-
nrc/regulatory/enforcement/enforce-pol.html. The apparent violation involves the failure to
design and prepare radioactive materials for shipment so that, under conditions normally
incident to transportation, the radiation level does not exceed 200 millirem per hour at any point
on the external surface of the package, as required by Title 49 of the Code of Federal
Regulations (49 CFR) 173.441. Pursuant to 10 CFR 71.5, licensees who deliver licensed
material to a carrier for transport must comply with the requirements of the U.S. Department of
Transportation regulations in 49 CFR Parts 171 through 180.
T. Via
2
In addition, since your facility has not been the subject of escalated enforcement actions within
the last 2 years, and based on our understanding of your corrective actions, a civil penalty may
not be warranted in accordance with Section 2.3.4 of the Enforcement Policy. The final decision
will be based on you confirming on the license docket that the corrective actions previously
described to the NRC staff have been or are being taken.
Before the NRC makes its enforcement decision, we are providing you an opportunity to:
(1) respond to the apparent violation addressed in this inspection report within 30 days of the
date of this letter or (2) request a pre-decisional enforcement conference (PEC). If a PEC is
held, it will be open for public observation and the NRC will issue a press release to announce
the time and date of the conference. Please contact Mr. Jeffrey Josey at 817-200-1249 or
Jeffrey.Josey@nrc.gov within 10 days of the date of this letter to notify the NRC of your
intended response to either provide a written response or participate in a PEC. A PEC should
be held within 30 days of the date of this letter.
If you choose to provide a written response, it should be clearly marked as a Response to
Apparent Violation in NRC Inspection Report (05000285/2024-004); EA-RIV-2024-0050 and
should include: (1) the reason for the apparent violation or, if contested, the basis for disputing
the apparent violation; (2) the corrective steps that have been taken and the results achieved;
(3) the corrective steps that will be taken; and (4) the date when full compliance will be
achieved. Your response may reference or include previously docketed correspondence, if the
correspondence adequately addresses the required response. To the extent possible, your
response should not include any personal privacy or proprietary information so that it can be
made available to the public without redaction.
Additionally, your written response should be sent to the U.S. Nuclear Regulatory Commission,
ATTN: Document Control Center, Washington, DC 20555-0001, with a copy to the Director,
Division of Radiological Safety & Security, Region IV, 1600 East Lamar Boulevard Arlington,
TX 76011, and emailed to R4Enforcement@nrc.gov, within 30 days of the date of this letter. If
an adequate response is not received within the time specified or an extension of time has not
been granted by the NRC, the NRC will proceed with its enforcement decision or schedule a
PEC.
If you choose to request a PEC, the conference will afford you the opportunity to provide your
perspective on these matters and any other information that you believe the NRC should take
into consideration before making an enforcement decision. The decision to hold a PEC does not
mean that the NRC has determined that a violation has occurred or that enforcement action will
be taken. This conference would be conducted to obtain information to assist the NRC in
making an enforcement decision. The topics discussed during the conference may include
information to determine whether a violation occurred, information to determine the significance
of a violation, information related to the identification of a violation, and information related to
any corrective actions taken or planned.
In presenting your corrective actions, you should be aware that the promptness and
comprehensiveness of your actions will be considered in assessing any civil penalty for the
apparent violations. The guidance in NRC Information Notice 96-28, Suggested Guidance
T. Via
3
Relating to Development and Implementation of Corrective Action, may be helpful in preparing
your response (Agencywide Documents Access and Management System (ADAMS) Accession
No. ML061240509).
Since the NRC has not made a final determination in this matter, a Notice of Violation is not
being issued for the apparent violation at this time. Please be advised that the characterization
of the apparent violation described in the enclosed inspection report may change as a result of
further NRC review. You will be advised by separate correspondence of the results of our
deliberations on this matter.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure,
a copy of this letter, its enclosure, and your response, if you choose to provide one, will be
made available electronically for public inspection in the NRC Public Document Room or in the
NRCs ADAMS, accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html.
If you have any questions regarding this inspection report, please contact Mr. Jeffrey Josey of
my staff at 817-200-1249.
Sincerely,
Jeremy R. Groom, Director (Acting)
Division of Radiological Safety and Security
Docket No. 050-00285
License No. DPR-40
Enclosure:
Inspection Report 050-00285/2024-004
Electronic Distribution via Listserv
Signed by Groom, Jeremy
on 02/04/25
SUNSI Review: ADAMS:
Non-Publicly Available Sensitive
Keyword:
By: ESM
Yes No
Publicly Available
Sensitive
OFFICE
HP:DIOR
SHP:DIOR
TL:ACES
C:DIOR
NAME
EMcManus
SAnderson
BAlferink
JJosey
SIGNATURE
/RA/ E
/RA/ E
/RA/
/RA/
DATE
01/27/25
01/27/25
01/29/25
01/29/25
OFFICE
RC
D:DRSS
NAME
DCylkowski
DBradley
JGroom
SIGNATURE
/RA/ E
/RA/ E
/RA/ E
DATE
01/29/25
01/31/25
02/04/25
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.
050-00285
License No.
Report No.
050-00285/2024-004
Licensee:
Omaha Public Power District
Facility:
Fort Calhoun Station
Location:
9610 Power Lane
Blair, Nebraska
Inspection Dates:
December 9-11, 2024
Exit Meeting Date:
January 22, 2025
Inspectors:
Eric S. McManus, Health Physicist
Decommissioning, ISFSI, and Operating Reactor Branch
Division of Radiological Safety and Security
Stephanie G. Anderson, Senior Health Physicist
Decommissioning, ISFSI, and Operating Reactor Branch
Division of Radiological Safety and Security
Accompanied By:
Tiffany N. Rushing, Health Physicist
Decommissioning, ISFSI, and Operating Reactor Branch
Division of Radiological Safety and Security
Approved By:
Jeffrey E. Josey, Chief
Decommissioning, ISFSI, and Operating Reactor Branch
Division of Radiological Safety and Security
Attachment:
Supplemental Inspection Information
2
EXECUTIVE SUMMARY
Fort Calhoun Station
NRC Inspection Report 050-00285/2024-004
This U.S. Nuclear Regulatory Commission (NRC) inspection was a routine, announced
inspection of decommissioning activities being conducted at the Fort Calhoun Station.
Decommissioning Performance and Status Reviews at Permanently Shutdown Reactors
The inspectors observed decommissioning work in progress and concluded that the work
was being conducted with an emphasis on industrial and radiological safety. Critical
positions in the organizational structure were staffed. No major changes in the schedule
were identified that had an impact on the decommissioning trust fund. The licensee
continued to identify problems and implement its corrective action program in accordance
with quality assurance program requirements. (Section 1.2)
Fire Protection Program at Permanently Shutdown Reactors
The licensee implemented the fire protection program in accordance with applicable
regulatory and procedure requirements. (Section 2.2)
Solid Radioactive Waste Management and Transportation of Radioactive Materials
In accordance with procedural instructions, Post-Shutdown Decommissioning Activities
Report (PSDAR) commitments, and regulatory requirements, the licensee is adequately
controlling radioactive materials and radioactive sources. (Section 3.2)
Apparent Violation
One apparent violation was identified for the Fort Calhoun Stations failure to properly prepare
and ship a package containing radioactive material in a manner that assured, under conditions
normally incident to transport, the radiation level does not exceed 200 millirem per hour at any
point on the external surface of the package, as required by Title 49 of the Code of Federal
Regulations (49 CFR) 173.441. Pursuant to 10 CFR 71.5, licensees who deliver licensed
material to a carrier for transport must comply with the requirements of the U.S. Department of
Transportation regulations in 49 CFR Parts 171 through 180. Specifically, the licensee shipped
a package containing radioactive materials (i.e., crushed concrete, metal debris, and lagoon
liner) such that when the package arrived at its destination on November 14, 2024, radiation
levels of approximately 765 mrem/hr were measured on the side of the railcar, exceeding the
regulatory requirement of 200 mrem/hr.
3
Report Details
Summary of Site Status
Fort Calhoun Station (FCS) permanently ceased power operations in 2016. In accordance with
Title 10 of the Code of Federal Regulations (10 CFR) 50.82(a)(9), an application for a license
termination must be accompanied or preceded by the license termination plan (LTP). The
licensee submitted its proposed LTP to the NRC in August 2021. The NRC conducted an
acceptance review and submitted two requests for additional information to the licensee. The
licensee subsequently submitted a revised LTP to the NRC in December 2023 (ML23346A152).
The NRC approved the LTP by license amendment dated January 31, 2024 (ML24019A167).
Since the previous inspection, the licensee conducted Final Status Surveys (FSS) of land areas
and the auxiliary building, continued demolition of the containment building interior, and
transported the containment demolition rubble for offsite disposal.
During the inspection, the licensee continued to decommission the interior of the containment
building. The waste material generated, including radioactive concrete and metal support
components, were transferred to the Waste Processing Structure (WPS) for sorting and
subsequent shipment to a disposal site. In addition, the licensee continued to conduct
radiological assessments, remedial action support surveys, and FSS at several locations around
the site.
1
Decommissioning Performance and Status Reviews at Permanently Shutdown
Reactors (IP 71801)
The inspectors observed site activities, reviewed selected records, and interviewed site
personnel to:
Evaluate the status of decommissioning and verify whether the licensee was
conducting decommissioning and maintenance activities in accordance with
regulatory and license requirements.
Maintain awareness of work activities to assess licensee control and conduct of
decommissioning.
Evaluate select licensee decommissioning staffing, personnel qualifications, and
training requirements, including that of the contracted workforce, to ensure that
license requirements were met, as applicable to the current decommissioning
status.
Identify and document the status, progress, and changes that potentially impact
decommissioning financial assurance, to supplement information for the
Financial Assurance Branch to support and ensure a thorough financial analysis
review of the annual decommissioning trust fund reported by the licensee.
1.2
Observations and Findings
a.
Status of Decommissioning
The inspectors conducted site tours, in part, to observe decommissioning activities in
progress. Inside containment, heavy equipment continued to remove the demolished
floor and walls and transport the removed materials to the WPS for sorting and loading
into railcar gondolas. Inside the WPS, the containment debris was crushed, surveyed,
4
sorted, and loaded into railcar gondolas for shipment to an out-of-state disposal site.
Outside of containment, work in progress included radiological surveys of various areas
around the site. Discharges of processed liquid was paused to protect the processing
and discharge equipment from freezing during the winter. The inspectors observed
licensee surveys were being conducted in accordance with the instructions provided in
Section 5 of the LTP. Finally, the inspectors validated that the licensee had updated the
Defueled Safety Analysis Report (DSAR) and had appropriately identified and stored
records important to decommissioning as defined in 10 CFR 50.75(g).
b.
Decommissioning Operations
The inspectors conducted a detailed review of shipping and survey records associated
with the loading of radioactive material being prepared for shipment. The inspectors also
observed surveys of heavy equipment moved to and from radiologically controlled areas.
The inspectors observed the sorting and handling of crushed containment concrete and
debris.
The inspectors conducted independent radiological assessments during site tours using
a hand-held survey meter, a Radeye G gamma survey meter (Serial Number 30901,
calibration due date January 19, 2025). The inspectors confirmed that radiological
postings and survey results were consistent with regulatory requirements.
During tours of the Containment Waste Structure (CWS) and WPS, the inspectors noted
appropriate use of radiation protection instruments and air samplers to minimize
employee exposures to radioactive contamination. Ventilation systems were in service to
control airflow within the structures. The RP technician response to portal monitor alarms
was observed; RP technicians responded and performed surveys in accordance with
licensee procedures to validate portal monitor alarms were not due to personnel
contamination events. The decommissioning work was being conducted with an
emphasis on industrial and radiological safety.
c.
Decommissioning Staffing and Training
The inspectors reviewed the organizational chart and confirmed that all critical positions
had been filled. The inspectors reviewed training records and lesson plans for the
licensees transportation broker training program. Initial training and refresher training
was conducted in accordance with regulations and licensee procedures. See the
evaluation details in transportation section (Section 3.2.b) of this report.
d.
Decommissioning Planning, Scheduling, and Cost Assessment
The inspectors interviewed senior licensee management and reviewed the licensees
decommissioning strategy and schedule, in part, to ensure there were no major changes
that would impact the decommissioning trust fund. No major changes were identified
during the inspection that would have a significant impact on the trust fund.
5
e.
Problem Identification and Resolution
Section 16 of the Quality Assurance Topical Report, revision 18, requires the licensee to
implement a corrective action program. The inspectors reviewed the most recent list of
corrective action Condition Reports (CR) issued since the last inspection in this program
area. No CRs of significance were identified.
1.3
Conclusions
The inspectors observed decommissioning work in progress and concluded that the
work was being conducted with an emphasis on industrial and radiological safety.
Critical positions in the organizational structure were staffed. No major changes in the
schedule were identified that had an impact on the decommissioning trust fund. The
licensee continued to identify problems and implement its corrective action program in
accordance with quality assurance program requirements.
2
Fire Protection Program at Permanently Shutdown Reactors (IP 64704)
2.1
Inspection Scope
The inspectors reviewed documents and interviewed plant personnel to assess the
licensees performance in the following areas:
Assessed whether the licensee has an effective decommissioning fire protection
program that is maintained and implemented to address the potential for fires
that could result in the release or spread of radioactive materials.
Verified that, in the absence of spent fuel in the spent fuel storage pool, the
decommissioning fire protection program ensures adequate protection from the
fire-induced release of radioactive material from contaminated plant areas and
combustible waste products.
Performed plant tours to assess field conditions and the storage of combustible
materials.
2.2
Observations and Findings
a.
Title 10 CFR 50.48(f) states, in part, that the licensee shall maintain a fire protection
program to address the potential for fires that could cause the release or spread of
radioactive materials onsite or result in a localized radiological hazard. The inspectors
reviewed the licensees fire protection program for compliance with regulatory and
license requirements. The inspectors reviewed the fire protection program as defined
by procedure CC-FC-211, Fire Protection Program, revision 14.
Regulatory Guide 1.191, Fire Protection Program for Nuclear Power Plants During
Decommissioning and Permanent Shutdown, describes the methods acceptable to
the NRC for complying with the NRCs regulations for fire protection programs for
licensees in decommissioning. This regulatory guide is referenced in the licensees
implementing procedures, and the inspectors compared the licensees fire protection
program to the guidance provided in the regulatory guide.
6
The licensees fire protection program records included a fire hazards analysis. This
document provided an analysis of the various plant areas and the fire protection
requirements for those areas. The licensee also developed a detailed decommissioning
fire plan procedure, FCSD-FP-100, Decommissioning Fire Plan, revision 9, that
described onsite fire response staffing, onsite fire response organization responsibilities,
pre-fire plans for the ISFSI Operating Facility and ISFSI area, and fire report preparation
after reportable fires.
The inspectors reviewed one assessment that evaluated the fire protection program in
accordance with 10 CFR 50.48(f)(2). The assessments showed that the fire protection
program was adequate at the site.
b.
Fire Protection Systems and Equipment
The inspectors reviewed the licensees ability to rapidly detect, control, and extinguish
fires. At this stage in decommissioning, the licensee has no automatic fire detection
systems and no automatic fire suppression systems within the deconstruction area at
the plant. The inspectors toured the CWS and the WPS and verified the fire
extinguishers were located according to the pre-fire plans. The fire extinguishers
monthly and annual surveillances were completed satisfactorily.
c.
Control of Combustible Materials and Ignition Sources
To prevent fires from occurring, the licensee established and implemented
administrative procedures for fire prevention control of transient combustible material
and control of ignition sources. The inspectors conducted site tours to confirm that
procedure controls were being implemented. The inspectors concluded that the
licensee was effectively controlling combustible materials around ignition sources in
these areas in accordance with procedure requirements.
d.
Organization
The inspectors reviewed the fire response organization at the site. Fire response
training is provided for all individuals assigned fire watch duties. The inspectors also
reviewed the memorandum of understandings with the offsite fire brigades, as they are
the primary responders in the case of a fire at the site.
e.
Problem Identification and Resolution
The inspectors reviewed a sample of CRs, and assessed the licensee is identifying
problems and entering them into their corrective action program appropriately.
2.3
Conclusions
The licensee implemented the fire protection program in accordance with
applicable regulatory and procedure requirements.
7
3
Solid Radioactive Waste Management and Transportation of Radioactive Materials
(IP 86750)
3.1
Inspection Scope
The inspectors observed site activities, reviewed documents, and interviewed site
personnel to verify the effectiveness of the licensees programs for processing, handling,
storage, and transportation of radioactive materials.
3.2
Observations and Findings
a.
Radioactive Material Storage and Control
The inspectors toured areas where radioactive materials are stored. Radioactive
material storage areas toured included the containment, radiologically controlled areas
adjacent to the containment structure, CWS, WPS, and waste processing equipment
storage areas. Sorting of containment rubble in the WPS identified concrete debris and
metal with high radiation levels. Inspectors observed the control and storage of the
higher radiation level material in a high radiation area vault located within the WPS. All
areas containing radioactive material were controlled, posted, and maintained in
accordance with regulations and licensee procedures.
The inspectors also reviewed procedures for and toured the area where Category 2
material was controlled in accordance with 10 CFR Part 37. The material were sources
used to calibrate radiation protection survey instruments. The licensee procedures,
physical barriers, and security personnel were sufficient to ensure control of the sources.
The licensee had not transferred or replaced the sources since the last inspection. RP
technicians demonstrated how the sources are verified intact and leak checked. RP
technicians also provided records of source inspections and leak checks.
b.
Radioactive Waste Processing
No active liquid waste processing occurred during this inspection and processed liquid
discharges were paused due to low outdoor temperatures. The inspectors toured the
areas where liquid waste storage, processing, and discharge equipment were located.
Liquid waste was being accumulated in storage tanks while liquid waste discharges were
suspended. All equipment associated with liquid processing was posted and controlled
in accordance with regulations. The equipment was also being maintained to prevent
damage or leaks caused by freezing temperatures.
In the WPS, the inspectors observed processing of demolition rubble from the
containment interior. Large concrete sections were crushed to smaller pieces or dust.
Metal debris was separated from the crushed debris and materials with higher radiation
levels were segregated for separate shipment. The inspectors noted adequate health
physics controls in all areas including the use of protective clothing, RP instruments and
air samplers to monitor employee exposures to radioactive contamination. The
inspectors also noted good use of industrial safety practices. Craft and RP personnel
worked together effectively to ensure safety while working near heavy equipment, large
rubble, and material with higher exposure rates.
8
c.
Transportation of Radioactive Materials
The inspectors reviewed training records and lesson plans for the licensees broker
training program. The inspectors performed a detailed audit training of records for two
certified brokers and ensured all training was up to date when the brokers signed
records for radioactive material shipments. Initial training and refresher training were
conducted in accordance with regulations and licensee procedures.
Apparent Violation
The inspectors performed a focused review of the November 6, 2024, radioactive
material shipment (Shipping Manifest Number 1072-07-0875) from FCS to the Clive
Disposal Facility (CDF) in Clive, UT.
Title 10 CFR 71.5 requires each licensee who delivers licensed material to a carrier for
transport to comply with the requirements of the DOT regulations in 49 CFR Parts 171
through 180. 49 CFR 173.441(a) requires in part, with exceptions not applicable here,
that each package of radioactive materials offered for transportation be designed and
prepared for shipment so that under conditions normally incident to transportation the
radiation level does not exceed 200 millirem per hour (mrem/hr) at any point on the
external surface of the package.
Contrary to the above, on November 6, 2024, the licensee failed to prepare a package of
radioactive material such that, under normal conditions incident to transport, the
radiation level did not exceed 200 mrem/hr at any point on the external surface of the
package. Specifically, the licensee shipped a package containing radioactive materials
(i.e., crushed concrete, metal debris, and lagoon liner) such that when the package
arrived at its destination on November 14, 2024, radiation levels of approximately
765 mrem/hr were measured on the side of the railcar, exceeding the regulatory
requirement of 200 mrem/hr.
Upon identification, CDF immediately notified FCS, then notified the Director of the Utah
Division of Waste Management and Radiation Control (Utah Event Report ID Number:
UT 240008, on November 15, 2024) and the NRC Operations Center (Event # 57440, on
November 25, 2024).
The immediate corrective actions taken by the licensee and its contractor included the
following actions. The contractor stopped all loading and shipment of loaded railcars
until further notice. CDF conducted an investigation to determine the cause of the high
contact dose rate and identified a small piece of concrete in the pile reading
approximately 986 mrem/hr on contact and 700 mrem/hr at 30 cm away. FCS
documented the issue in its corrective action program (CR-2024-00198) and conducted
an Apparent Cause Analysis (ACA). The FCS ACA stated that the small piece of
concrete migrated within the container during transport to the side of the container
resulting in an increased radiation level accessible on the external surface of the
railcar. Also, per the ACA, a review of the process steps identified that there were no
procedural requirements to be more intrusive in the debris piles to locate pieces that
may have higher dose rate readings, and the most logical reasoning for not catching the
986 mrem/hr piece of concrete is that it was buried in the larger pile(s) being loaded.
FCS conducted an evaluation to determine the maximum dose received by unmonitored
9
members of the public during shipment. The licensee determined that no member of the
public could have received a dose greater than 1 mrem while the railcar was in transit.
FCS revised the container loading work instruction WI-2021-109, DWP-2021-011 Waste
Processing Structural Operations, revision 3, which changed the order in which differing
material types are loaded into the container and reduced the radiation level limit from
700 mrem/hr to 50 mrem/hr for individual concrete debris permitted to be loaded into the
LSA-1 containers. The revised procedure also added steps to perform radiation surveys
of crushed concrete. Prior to the work instruction revision, this material was only
surveyed prior to crushing.
The inspectors arrived onsite after the work instruction was revised. The inspectors
reviewed the licensee container loading procedures used prior to the apparent violation
and validated that all applicable procedures were followed during preparation and
loading of the rail shipment. The inspectors observed the implementation of the revised
work instruction during loading of railcars at the WPS. The inspectors observations
validated that the revised work instruction appeared to be effective in preventing
additional railcars from exceeding the DOT external radiation limit. The inspectors
observed that RP technician surveys were effective in identifying crushed concrete with
radiation levels greater than 50 mrem/hr and craft personnel were removing the higher
reading material to ensure it was not loaded into the railcars. After all corrective actions
were implemented, FCS resumed shipment of railcars loaded with containment interior
crushed rubble.
The licensees failure to prepare a package of radioactive material such that, under
normal conditions incident to transport, the radiation level did not exceed 200 mrem/hr
at any point on the external surface of the package, is identified as an apparent violation
of 10 CFR 71.5 (05000285/2024-004-01)
d.
Problem Identification and Resolution
The inspectors conducted a review of CRs issued since the last inspection of this area.
The inspectors review and interviews with RP personnel validated that the licensee
appears effective at identifying problems and implementing corrective actions.
3.3
Conclusions
In accordance with procedural instructions, PSDAR commitments, and regulatory
requirements, the licensee is adequately controlling radioactive materials and radioactive
sources. In the area of radioactive material transportation, one apparent violation of DOT
regulations was identified that is being considered for escalated enforcement. The
violation involved the licensees failure to prepare a package of radioactive material for
transportation such that, under conditions normally incident to transportation, the
radiation level did not exceed 200 mrem/hr at any point on the external surface of the
package.
10
4
Exit Meeting Summary
The inspectors presented the preliminary inspection results to the licensees
management and other members of the licensees staff at the conclusion of the onsite
inspection on December 11, 2024. A final exit meeting was held with the licensees
senior management and staff on January 22, 2025. The inspectors asked if any
materials examined were proprietary. No proprietary information was removed from the
site.
Attachment
SUPPLEMENTAL INSPECTION INFORMATION
KEY POINTS OF CONTACT
Licensee and Contractor Personnel
B. Pearson, Regulatory Assurance & Emergency Planning Manager
K. Daughenbaugh, ISFSI Shift Supervisor
T. Uehling, Director Site Decommissioning
A. Hansen, Regulatory Assurance
C. Heimes, Manager ISFSI Site Security
A. Kodra, Project Manager FSS, EnergySolutions
J. Emich, Waste Project Manager
T. Maine, Plant Manager
J. Nowak, Project Director, EnergySolutions
D. Whisler, RP & Chemistry Specialist
J. Hoffman, Chemistry Specialist
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
05000285/2024-004-01
Radioactive Material Shipment Package Dose Rate
Exceeded (49 CFR 173.441)
Closed
None
Discussed
None
INSPECTION PROCEDURES USED
Decommissioning Performance and Status Reviews at Permanently Shutdown
Reactors
Fire Protection Program at Permanently Shutdown Reactors
Solid Radioactive Waste Management and Transportation of Radioactive
Materials
LIST OF ACRONYMS
Agencywide Documents Access and Management System
ACA
Apparent Cause Analysis
Apparent violation
Clive Disposal Facility
CFR
Code of Federal Regulations
Containment Waste Structure
CR
Condition Report
U.S. Department of Transportation
Defueled Safety Analysis Report
Fort Calhoun Station
Final Status Survey
IP
Inspection Procedure
Independent Spent Fuel Storage Installation
2
License Termination Plan
NRC
Nuclear Regulatory Commission
PEC
Pre-Decisional Enforcement Conference
Post-Shutdown Decommissioning Activities Report
Radiation Protection
WPS
Waste Processing Structure