IR 05000302/2024002
| ML25071A202 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 03/13/2025 |
| From: | Eve E NRC Region 1 |
| To: | Reid B ADP CR3 |
| References | |
| IR 2024002 | |
| Download: ML25071A202 (1) | |
Text
March 13, 2025
SUBJECT:
ACCELERATED DECOMMISSIONING PARTNERS (ADP) CR3, LLC, CRYSTAL RIVER UNIT 3 - NRC INSPECTION REPORT NO. 05000302/2024002
Dear Billy Reid:
On December 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection under Inspection Manual Chapter 2561, Decommissioning Power Reactor Inspection Program, at the permanently shut down Crystal River Nuclear Plant Unit 3 (CR3). The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's 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 January 29, 2025, 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 document system (ADAMS), accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.
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, Elise Eve, Team Leader Decommissioning Team Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Radiological Safety and Security
Docket No.
05000302 License No. DPR-72 cc w/encl: Distribution via ListServ Enclosure:
Inspection Report No. 05000302/2024002 ELISE EVE Digitally signed by ELISE EVE Date: 2025.03.13 13:34:17 -04'00'
ML25071A202 OFFICE DRSS/RI
DRSS/RI
NAME SVeunephachan/sv EEve/ee
DATE 03/013/2025 03/13/2025
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Nos.
05000302
License Nos.
Report Nos.
Licensee:
Accelerated Decommissioning Partners CR3, LLC (ADP)
Facility:
Crystal River Unit 3 (CR3)
Location:
Crystal River, FL
Inspection Dates:
July 1, 2024 - December 31, 2024
Inspectors:
Storm Veunephachan, Senior Health Physicist
Decommissioning, ISFSI, and Reactor Health Physics Branch
Division of Radiological Safety and Security
Gunnar Eklund, Health Physicist
Decommissioning, ISFSI, and Reactor Physics Branch
Division of Radiological Safety and Security
Approved By:
Elise Eve, Team Leader
Decommissioning Team
Decommissioning, ISFSI and Reactor Health Physics Branch
Division of Radiological Safety and Security
EXECUTIVE SUMMARY
Accelerated Decommissioning Partners CR3, LLC (ADP)
Crystal River Unit 3
NRC Inspection Report No. 05000302/2024002
An announced decommissioning inspection was completed on December 31, 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 NRC's 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 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 No. DPR-72 for CR3 and the general
license for the CR3 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.
CR3 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
The inspectors performed on-site decommissioning inspection activities on August
12 - 16, 2024, October 21 - 24, 2024, December 09 - 12, 2024 and supplemented by
in-office reviews and periodic phone calls. The inspection consisted of observations by
the inspectors, interviews with site personnel, a review of procedures and records, and
site walk-downs.
2.1
IP 40801, Problem Identification and Resolution at Permanently Shutdown Reactors
a. Inspection Scope
The inspectors assessed the implementation and effectiveness of ADPs Corrective
Action Program (CAP) by reviewing a sampling of issues, non-conformances, and any
conditions adverse to quality that were entered into the CAP. The inspectors reviewed
a representative selection of CAP documents to determine if a sufficiently low threshold
for problem identification existed, if follow-up evaluations were of sufficient quality, and
if ADP assigned timely and appropriate prioritization for issue resolution commensurate
with issue significance. The inspectors attended several management review
committee meetings to determine if ADP management was engaged in issue
disposition and resolution. Additionally, the inspectors interviewed site personnel
responsible for the CAP. The inspectors reviewed site audits for the past year to
determine if they were thorough and that corrective actions were initiated if necessary.
The inspectors interviewed the Employee Concerns Program representatives and
several employees to assess site safety culture.
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 review and
discussion. The inspectors noted adequate management engagement during
management review committee meetings. The inspectors determined that the quality
assurance organization was sufficiently independent and that the audits and self-
assessments conducted included appropriate scrutiny of licensee performance. The
inspectors verified that audits were performed by qualified individuals independent of
the organization being audited and that management reviewed the audits, self-
assessments, and associated corrective actions. The inspectors verified that the audits
and self-assessments were performed in the appropriate timeframe and any
weaknesses identified were captured within the CAP. The inspectors determined that
the site had an appropriate focus on a safety conscious work environment and that
employees were free to raise concerns.
c. Conclusions
No violations of more than minor significance were identified.
2.2
IP 71801 Decommissioning Performance and Status Reviews at Permanently
Shutdown Reactors
a. Inspection Scope
The inspectors reviewed documentation and met with ADP management to discuss
staffing, status of decommissioning and upcoming activities, among other topics to
verify whether the licensee had conducted activities in accordance with regulatory and
license requirements. The inspectors performed several plant walk-downs to assess
field conditions and decommissioning activities by assessing material condition of
structures, systems, and components, housekeeping, system configurations, and
worker level of knowledge or procedure use and adherence. These walk-downs
included all levels of the reactor building, auxiliary building, waste loadout area and
select final status survey units. The inspectors observed select pre-job briefs for reactor
building demolition and waste loadout.
The inspectors reviewed documentation and discussed with ADP and Duke Energy the
overall financial status of decommissioning for Crystal River and evaluated the use of
decommissioning trust funds to determine if they were appropriately used in
accordance with regulatory requirements. The inspectors also discussed any significant
changes to the estimated cost for, and any potential significant delays to, the
decommissioning schedule.
b. Observations and Findings
The inspectors noted that during this inspection period, ADP prepared for and began
internal reactor building demolition and finishing internal auxiliary building demolition.
The inspectors observed staging and preparation for reactor coolant bleed tank
dismantlement and removal and preparations for open air demolition for the auxiliary
building. This included conducting walk-downs across all levels of the auxiliary building
where there has been scabbling and other decontamination efforts. The inspectors also
reviewed the multi-phase auxiliary building demolition plan. The inspectors observed
open air demolition of the auxiliary building once internal demolition was completed.
The inspectors observed internal demolition of the D-rings for the reactor building. This
was completed by conducting walk-downs and observing the work area and observing
the waste loadouts for the debris. The inspectors observed final large bore piping
removal inside the reactor building. The inspectors reviewed the reactor building
demolition plans. The inspectors noted that, for the areas of the plant toured, the
material condition and housekeeping were adequate. The inspectors determined that
staffing was appropriate for the current stage of decommissioning and training
programs were being appropriately implemented.
The inspector reviewed financial assurance documentation, including the annual report
on the status of decommissioning funding and met with ADP and Duke Energy staff to
determine whether the funds were used as expected and if any changes could
significantly impact the sites decommissioning financial assurance. The inspectors
determined that the licensee has used funds in accordance with regulatory
requirements and have no significant deviations from the decommissioning schedule.
c. Conclusions
No violations of more than minor significance were identified.
2.3
IP 83750, Occupational Radiation Exposure at Permanently Shutdown Reactors
a. Inspection Scope
The inspectors observed activities, reviewed documentation, and interviewed
personnel associated with occupational radiation exposure to determine the adequacy
of protection of worker health and safety. The inspectors conducted site walk-downs to
verify and assess radiological postings and contamination boundaries. The inspectors
observed RP technicians performing job coverage and surveys to determine if
implementation of radiological work controls, training and skill level, and
instrumentation were sufficient for the activities being performed. The inspectors
reviewed radiation work permits to determine if radiation work activities were pre-
planned effectively to limit worker exposure. The inspectors reviewed the radiation
protection survey plan to prepare for open air demolition of the auxiliary building and
the open-air demolition air sampling plan. The inspectors reviewed dose records to
determine if occupational doses were within regulatory limits. The inspectors observed
several instrument source checks and calibrations to assess function and proper use of
the instruments. The inspectors reviewed bioassay procedures and compensatory
measures.
The inspectors reviewed documentation and conducted walk-downs of select sealed
sources to ensure ADP maintained adequate controls. These reviews included leak
test records and physical verification checks.
b. Observations and Findings
The inspectors verified technician training and qualifications were up to date. The
inspectors verified that radiological work was planned, and post job reviews were
performed as needed and were effective in limiting worker exposure and occupational
dose was acceptable for the scope of the radiological activities performed. The
inspectors determined that RP (Radiation Protection) staff effectively controlled work
activities, survey records were clear and complete, and RP technicians used
appropriate instruments for the surveys. The inspectors verified technician training and
qualifications were up to date. The inspectors determined that the licensee
performance of source and calibration checks were adequately performed, and the
staff conducting these activities was sufficiently knowledgeable of the instruments and
the site procedures. The inspectors notably observed source checks of handheld
radiation instrumentation as well as personnel monitoring instrumentation to prevent
the release of radioactive material. The inspectors interviewed RP staff for bioassay
methods and measurements. The inspectors noted that there had been no required
bioassay measurements taken but reviewed all bioassay procedures and
compensatory measures. The inspectors determined that the sites sealed sources
were leak tested with the appropriate frequency and were controlled adequately.
The inspectors observed the smearing and surveying of trucks exiting the radiological
controlled area and unloading of concrete debris to ensure there was no spread of
radioactive material. The inspectors conducted walk-downs of the air sampling stations
located around the open-air demolition of the auxiliary building and the dust mitigation
efforts by multiple misters. The inspectors determined the radiological surveying of
trucks was adequate to control the release of radioactive material and the air sampling
stations were positioned in accordance with the sites air sampling plan for open air
demolition.
c. Conclusions
No violations of more than minor significance were identified.
2.4
IP 83801, Inspection of Remedial and Final Surveys at Permanently Shutdown
Reactors
a. Inspection Scope
The inspectors reviewed documentation related to Final Status Surveys (FSS) that
included remediation plans for select areas and at-risk FSS areas. The inspectors
observed remediation and final status surveying of a select area and observed
radiation instrumentation source checks and chain of custody controls.
b. Observations and Findings
The inspectors observed piping removal and subsequent final status surveying. The
inspectors note that this is at-risk and is demarcated as such within the survey plans
until final license termination plan approval. The inspectors determined that the
instruments used for final status surveying were adequately source checked with
adequate chain of custody controls.
c. Conclusions
No violations of more than minor significance were identified.
2.5
IP 84704, Radioactive Waste Treatment, and Effluent and Environmental Monitoring
a. Inspection Scope
The inspectors reviewed activities and documentation associated with radioactive
effluent control and site radiological environmental monitoring program (REMP) to
assess the effectiveness of site radiological programs. The inspectors reviewed liquid
effluent batch release permits, licensee audits, the annual radioactive effluent release
report, and the annual radiological environmental operating report. The inspectors
toured selected environmental monitoring stations to determine the adequacy of
location of instrumentation and observed sampling of groundwater and collection of air
monitor samples. The inspectors conducted walk-downs of selected effluent release
treatment system and monitoring points and reviewed 10 CFR 50.75(g) recordkeeping
practices and selected records. The inspectors conducted walkdowns of the effluent
treatment system modified in the prior inspection period and reviewed under the 10 CFR 50.59 process applicability determination.
b. Observations and Findings
The inspectors verified that effluent releases to the environment had been properly
controlled, monitored, and quantified as required by NRC regulations. The inspectors
verified that the long-term groundwater monitoring report, the annual radioactive
effluent release report, and the annual radiological environmental operating report
demonstrated that calculated doses were below regulatory dose criteria listed in 10 CFR 50, Appendix I. The inspectors verified that ADP maintained records as required
by 10 CFR 50.75(g) and had the ability to promptly access specific records requested
by the inspectors. Additionally, the inspectors verified effluent sampling equipment
were checked, calibrated, and maintained as specified in the ODCM. The inspectors
verified sampling stations were accessible and as described in the ODCM. The
inspectors verified the ODCM has been updated from its current revision. The
inspectors verified the effluent treatment system was adequately described and
modified to treat radioactive effluents for batch releases.
c. Conclusions
No violations of more than minor significance were identified.
2.6
IP 86750, Solid Radioactive Waste Management and Transportation of Radioactive
Materials
a. Inspection Scope
The inspectors observed activities, interviewed personnel, performed walkdowns, and
reviewed documentation to assess the licensees programs for handling, storage, and
transportation of radioactive material. The inspectors observed workers handling and
packaging radioactive waste and performed walk-downs of radioactive waste storage
locations, including the waste loadout area, temporary radioactive material storage in
the reactor building and auxiliary building. The inspectors observed personnel
surveying, labeling, and placarding vehicles used for transporting radioactive waste
and reviewed work packages for shipments of radioactive waste. The review included
records of shipment packaging, surveying, labeling, marking, placarding, vehicle
checks, and emergency instructions to determine compliance with NRC and
Department of Transportation (DOT) regulations. The inspectors reviewed training
records to determine if radwaste personnel were qualified to implement the site solid
radwaste program.
b. Observations and Findings
The inspectors determined that solid radioactive waste was adequately stored and
monitored and worker radwaste training and qualifications were up to date. The
inspectors determined that radioactive waste shipping paperwork was properly
completed, and ADP and ADP contractor personnel were knowledgeable of their duties
and responsibilities. The inspectors determined that radioactive waste shipped was
properly described, classified, packaged, marked, and labeled, and was in proper
condition for transport. The inspectors determined that ADPs radwaste shipments
were in compliance with NRC and DOT regulations. Specifically, the inspectors
reviewed the radioactive waste shipment packages for the reactor coolant bleed tanks.
c. Conclusions
No violations of more than minor significance were identified.
4.0 Exit Meeting Summary
On January 29, 2025, the inspectors presented the inspection results to Billy Reid, Site
Vice President, and other members of the ADP organization. No proprietary information
was documented in this report