ML25071A202

Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3 NRC Inspection Report No. 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

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 475 ALLENDALE ROAD, SUITE 102 KING OF PRUSSIA, PA 19406-1415 March 13, 2025 Billy Reid, Jr.

Site Vice President ADP CR3, LLC 15760 West Power Line St.

Crystal River, FL 34428

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.

DPR-72 Report Nos.

05000302/2024002 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

2 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.

3 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.

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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.

5 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.

6 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.

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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

8 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