LIC-25-0003, Response to Apparent Violation in NRC Inspection Report 05000285/2024004
| ML25063A277 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  (DPR-040) |
| Issue date: | 02/26/2025 |
| From: | Pearson B Omaha Public Power District |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| EA-RIV-2024-0050, IR 2024-004, LIC-25-0003 | |
| Download: ML25063A277 (1) | |
Text
444 S 16th Street Mall x Omaha, NE 68102-2247 LIC-25-0003 IR 2024-004 February 26, 2025 EA-RIV-2024-0050 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station (FCS), Unit 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285
Subject:
Response to Apparent Violation in NRC Inspection Report (05000285/2024-004-01)
EA-RIV-2024-0050
References:
1.
Letter from NRC to OPPD (T. Via), Fort Calhoun Station - NRC Inspection Report 050-00285/2024-004, dated February 4, 2025 (ML25027A457)
By letter dated February 4, 2025, (Reference 1), the Nuclear Regulatory Commission (NRC) issued apparent violation, EA-RIV-2024-0050, to Omaha Public Power District (OPPD), Fort Calhoun Station (FCS). The letter documents a violation of the requirements of 10 CFR 71.5 and provides an opportunity to respond to the apparent violation within 30 days of the date of the letter.
OPPD acknowledges the violation and has taken corrective steps to avoid further violations. The OPPD response to the apparent violation is attached.
This letter contains no regulatory commitments.
ADAMS Accession # ML25063A277
U. S. Nuclear Regulatory Commission LIC-25-0003 Page 2 If you should have any questions regarding this submittal or require additional information, please contact me at bpearson@oppd.com or 531-226-7249.
Respectfully, Benjamin P. Pearson Regulatory Assurance and Emergency Planning Manager Energy Production and Nuclear Decommissioning : Response to Apparent Violation in NRC Inspection Report (05000285/2024-004-01) EA-RIV-2024-0050 cc:
J. D. Moninger, NRC Regional Administrator, Region IV J. D. Parrott, NRC Senior Project Manager S. Anderson, NRC Health Physicist, Region IV
Response to Apparent Violation in NRC Inspection Report (05000285/2024-004-01) EA-RIV-2024-0050 Page 1 of 3 By letter dated February 4, 2025, the Nuclear Regulatory Commission (NRC) issued an apparent violation to Omaha Public Power District (OPPD) Fort Calhoun Station (FCS). The letter documents a violation of the requirements of 10 CFR 71.5 for the 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. The letter provides the opportunity to respond to the apparent violation within 30 days of the date of the letter.
OPPD does not dispute the apparent violation and provides the following response per the letter guidance.
Restatement of the apparent violation:
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.
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.
- 1. Reason for Apparent Violation The apparent cause of this violation was determined to be insufficient methods for packaging and surveying containment debris. Specifically, the process did not account for the need to spread out debris and conduct surveys on smaller piles to ensure higher dose pieces of concrete could be identified and segregated. A contributing cause was the lack of an enhanced surveillance program for the changing conditions to identify, segregate, and package separately the increasing higher dose material.
- 2. Corrective Steps That Have Been Taken and Results Achieved x
Upon notification of the apparent violation, all loading and shipping activities were immediately suspended.
x In accordance with Clive Disposal Facility notification requirements for deficient shipments, a formal written notice (CD-2024-234) was submitted to the Director of the Utah Division of Waste Management and Radiation Control by the EnergySolutions Environmental Engineer and Manager.
Response to Apparent Violation in NRC Inspection Report (05000285/2024-004-01) EA-RIV-2024-0050 Page 2 of 3 x
An extent of condition review was conducted to ensure that the 12 railcars shipped on November 13, 2024, prior to Clive notification of deficiency on November 14, 2024, were not subject to a similar condition. The railcars were received at Clive Disposal Facility on November 22, 2024, with no violations.
x A comprehensive evaluation of the impact to the public due to the elevated radiation levels during transport was performed. Results confirmed that no member of the public could have received a dose greater than 1 mrem while the railcar was in transit.
x Corrective measures were developed in collaboration with Project and Senior Leadership, including:
o Segregation of all lagoon liner material as a separate commodity to prevent comingling.
o Commodity approval by Site Leadership for compliance prior to loading.
o Cursory contact dose rate surveys of railcar exterior surfaces after each commodity loaded.
o Site Leadership and Clive Disposal Facility Management reviewed actions taken prior to recommencing shipments.
x Work Instruction WI-2021-109 was revised to address additional controls and surveillance of interior containment demolition materials prior to loading. Revisions include:
o Checking containment interior concrete for contact dose rates prior to crushing.
o Segregating metal debris from concrete.
o Surveying of concrete and metal debris loaded to a supersack prior to loading into a rail car. The supersack packaging location within a rail car and the surveyed dose rates will be communicated to the Clive Disposal Facility.
x Read and Sign discussions with key personnel were conducted regarding updated work instructions. Topics included:
o Pre-job brief to review revised work instructions o Pre-surveying and segregation of material o Post-downsizing surveys to ensure compliance o Specific loading protocols for materials undergoing intrusive surveys x
Enhanced monitoring protocols were implemented. Enhancements include:
o Intrusive surveys for containment interior demolition materials exceeding 50 mRem/hr on contact.
o Screening of all containment interior demolition materials, including bulk material in the Waste Processing Structure, prior to loading. Note that this enhanced screening is for waste material that is likely to contain elevated dose items, which is currently limited to only containment interior waste material.
Implementation and completion of the above actions has created a more robust process to ensure no recurrence of the issues described in the violation.
Response to Apparent Violation in NRC Inspection Report (05000285/2024-004-01) EA-RIV-2024-0050 Page 3 of 3
- 3. Corrective Steps That Will Be Taken All planned actions have been completed.
- 4. Date When Full Compliance Will Be Achieved Full compliance was achieved on December 3, 2024, when all corrective actions were fully implemented.