IR 05000285/2024001

NRC Inspection Report 05000285/2024001

ML24145A111
Person / Time
Site:	Fort Calhoun
Issue date:	06/05/2024
From:	Greg Warnick NRC/RGN-IV/DRSS/DIOR
To:	Via T Omaha Public Power District
Dennes C
References
IR 2024001
Download: ML24145A111 (16)

Text

June 05, 2024

SUBJECT:

FORT CALHOUN STATION - NRC INSPECTION REPORT 05000285/2024-001

Dear Troy Via:

This letter refers to the U.S. Nuclear Regulatory Commission (NRC) decommissioning inspection conducted March 11-14, 2024 & May 6-9, 2024, at the Fort Calhoun Station near Blair, Nebraska. The NRC inspectors discussed the results of the decommissioning inspection with members of your staff at the conclusion of the onsite inspection. The inspection results are documented in the enclosure to this letter.

The NRC inspection examined 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 decommissioning performance, safety review and design change procedures, transportation and storage of radioactive waste, problem identification and resolution, and conduct of remedial and final status surveys. No violations were noted, and no response to this letter is required.

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 from the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response, if you choose to provide one, should not include any personal privacy or proprietary information so that it can be made available to the public without redaction. If you have any questions regarding this inspection report, please contact Christian Dennes at 301-415-3741 or the undersigned at 817-200-1249.

Sincerely, Gregory G. Warnick, Chief Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Docket No. 050-00285 License No. DPR-40 Enclosure:

Inspection Report 050-00285/2024-001 Electronic Distribution via Listserv Anderson, Stephanie signing on behalf of Warnick, Gregory on 06/05/24

SUNSI Review ADAMS: Sensitive Non-Publicly Available Keyword By:CRD2 Yes No Non-Sensitive Publicly Available NRC-002 OFFICE HP: DRSS/DIOR HP: DRSS/DIOR C: DRSS/DIOR NAME CRDennes MTJohnson GGWarnick SIGNATURE /RA/ /RA/ /RA/

DATE 05/29/24 05/29/24 06/05/24

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No. 050-00285

License No. DPR-40

Report No. 050-00285/2024-001

Licensee: Omaha Public Power District

Facility: Fort Calhoun Station

Location: 9610 Power Lane Blair, Nebraska

Dates: March 11-14, 2024 & May 6-9, 2024

Inspectors: Christian R. Dennes, Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security

M. Troy Johnson, Senior Health Physicist Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security

Accompanied By: Gregory G. Warnick, Chief Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security

Approved By: Gregory G. Warnick, Chief Decommissioning, ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security

Attachment EXECUTIVE SUMMARY

Fort Calhoun Station NRC Inspection Report 050-00285/2024-001

This U.S. Nuclear Regulatory Commission (NRC) inspection was a routine, announced inspection of decommissioning activities being conducted at the Fort Calhoun Station. In summary, the inspectors concluded that the licensee was conducting activities in accordance with site procedures, license requirements, and applicable NRC regulations.

Decommissioning Performance and Status Reviews at Permanently Shutdown Reactors

• The licensee conducted decommissioning and maintenance activities in accordance with license and regulatory requirements. The inspectors determined that the licensee was adequately controlling decommissioning activities and radiological work areas at the facility. Staffing level and qualification were appropriate and commensurate with current decommissioning activities. (Section 1.2)

Problem Identification and Resolution at Permanently Shutdown Reactors

• The licensee and its decommissioning contractor were identifying, resolving, and correcting issues, as well as conducting audits and assessments in accordance with their procedures and federal regulations. (Section 2.2)

Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors

• The licensees surveys which were validated by the NRCs contractor, show that the permanently shutdown power reactor site has not been decontaminated to acceptable residual radioactivity levels in accordance with the LTP. (Section 3.2)

Occupational Radiation Exposure at Permanently Shutdown Reactors

• The licensee was ensuring adequate protection of worker health and safety from exposure to radiation or radioactive material. (Section 4.2)

Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors

• The licensee was prepared to implement its safety review program in accordance with site procedures and regulatory requirements. (Section 5.2)

Solid Radioactive Waste Management and Transportation of Radioactive Materials

• The licensees contractor conducted waste management and transportation activities in accordance with the waste management plan, procedural instructions, Post-Shutdown Decommissioning Activities Report commitments and regulatory requirements. (Section 6.2)

Report Details

Summary of Plant Status

Fort Calhoun Station permanently ceased power operations in 2016. In accordance with Title 10 to the Code of Federal Regulations (10 CFR) 50.82(a)(4), the licensee submitted a Post-Shutdown Decommissioning Activities Report (PSDAR) to the NRC in 2017. The PSDAR was revised in 2019 and 2020 (Agencywide Documents Access and Management System [ADAMS]

Accession Numbers ML19351E355 and ML21271A605). The PSDAR contains a description of the planned decommissioning activities along with a schedule for their accomplishment.

10 CFR 50.82(a)(9) specifies that an application for 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 responded to the requests and subsequently submitted a revised LTP to the NRC on December 6, 2023 (ML23346A152).

At the time of the inspection, the licensee and its decommissioning contractor had removed all power from the containment structure and was actively removing large components. Alpha Steam generator A and the pressurizer were being prepared for shipment offsite for disposal.

Additionally, the contractor was actively demolishing portions of the biological shield to gain access to steam generator B for removal and subsequent preparation for shipment off site for disposal.

1 Decommissioning Performance and Status Review at Permanently Shutdown Reactors (IP 71801)

1.1 Inspection Scope

The inspectors observed site activities, reviewed materials, 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.

• To maintain awareness of work activities to assess licensee control and conduct of decommissioning.

• To 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.

1.2 Observations and Findings

a. Status of Decommissioning

The inspectors attended site status and Project Review Committee meetings and noted that the review, assessment, and scheduling of facility decommissioning, as well as problem identification were adequate. Additionally, the inspectors discussed with licensee the status of decommissioning activities and noted them to be on schedule commensurate with challenges encountered.

The inspectors evaluated whether required maintenance was being conducted at an appropriate frequency and that preventative maintenance, as appropriate, was being performed and documented adequately to support decommissioning operations.

b. Decommissioning Operations

The inspectors performed plant tours including radiological control areas and the reactor containment to assess field conditions and decommissioning activities. Material condition of structures, systems, and components, housekeeping, system configurations, worker level of knowledge, as well as procedure use and adherence, were noted to be good relative to the status of decommissioning. The inspectors observed active remediation of the auxiliary building and noted the engineering controls in the work plans were appropriately implemented to protect the public and the environment.

The inspectors evaluated whether the licensee's organization and staffing were appropriately adjusted for changes in the status of decommissioning, specifically noted was the licensees cross qualification of final status survey staff with radiation protection staff to augment final status survey operations as the decommissioning process continues. The inspectors determined the licensee was taking appropriate staffing action to ensure reasonable assurance of safety and security in accordance with regulatory requirements and the license.

c. Decommissioning Staffing and Training The inspectors reviewed select radiation protection and transportation staff training records to determine if they were trained in accordance with license and regulatory requirements as well as verify that qualifications and training were current. No discrepancies were noted.

d. Problem Identification and Resolution

The inspectors reviewed a sample of deficiencies documented in the Corrective Action Program (CAP) and verified that the licensee had identified and implemented appropriate corrective actions.

1.3 Conclusion

The licensee conducted decommissioning and maintenance activities in accordance with license and regulatory requirements. The inspectors determined that the licensee was adequately controlling decommissioning activities and radiological work areas at the facility. Staffing level and qualification were appropriate and commensurate with current decommissioning activities. No findings of significance were identified.

2 Problem Identification and Resolution at Permanently Shutdown Reactors (IP 40801)

2.1 Inspection Scope

The inspectors reviewed the licensees CAP related to the oversight of the shutdown reactor:

• To evaluate the effectiveness of licensee controls in identifying, resolving, and correcting issues in accordance with the NRC approved Quality Assurance (QA) Program and 10 CFR Part 50, Appendix B, Criterion XVI.

• To determine whether the audits and assessments were conducted in accordance with the requirements of the NRC-approved QA program and 10 CFR Part 50, Appendix B.

• To confirm that the licensee has established, implemented, and performed management reviews of the safety conscious work environment.

2.2 Observations and Findings

a. Corrective Action Programs

The inspectors reviewed the details of the contractors program in procedure FCSI-RA-301, Information Use Decommissioning Corrective Action Program, revision 3.

Additionally, the inspectors interviewed both CAP program managers about program trends, challenges faced, management engagement, and future for improvement and development items or plans.

The inspectors assessed the licensees effectiveness at reasonably preventing problems and promptly detecting and correcting issues of concern, conditions adverse to quality, and non-conformances. The inspectors determined that the licensee is adequately performing their CAP and meeting regulatory requirements.

b. Quality Assurance Audit Programs

Quality assurance audits are required by 10 CFR Part 50, Appendix B, Criterion XVIII.

Details of the programs are provided in procedure DD-QA-PN-006, QA Program Implementation Plan for the Fort Calhoun Decommissioning Services Project, revision 4. The inspectors reviewed audits and assessments to verify that the audits were being performed consistent with the schedule outlined in the QA program plan.

The inspectors interviewed staff and reviewed documents that demonstrate compliance with 10 CFR Part 50 Appendix B, Criterion XVIII. Both the licensee and its decommissioning contractor maintained a robust and regularly scheduled audit and surveillance program. The inspectors reviewed the 2023-2039 Master Audit Schedule, revision 3, and determined that the Master Audit Schedule is adequately following the proper frequency requirements provided in Chapter 18 and Appendix D of the NO-FC-10, Quality Assurance Topical Report, revision 17.

c. Safety Conscious Work Environment

The inspectors reviewed licensee-initiated safety culture assessments, by interviewing staff, the Employee Concerns Program manager, and the Nuclear Oversight manager.

Both program managers were engaged with the work force and had regular as well as meaningful interaction with management. The licensees program was described in procedure FCSI-RA-307, Information Use Safety Culture, revision 1, which used to be completed by Nuclear Oversight, but transitioned to Ethics Point. The inspectors determined that the licensee had an adequate safety conscious work environment that followed procedure and regulatory requirements.

2.3 Conclusion

The licensee and its decommissioning contractor were identifying, resolving, and correcting issues, as well as conducting audits and assessments in accordance with their procedures and federal regulations.

3 Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors (IP 83801)

3.1 Inspection Scope

The inspectors independently gathered sufficient information to determine whether licensee performance meets the following objectives:

• To verify that the permanently shutdown power reactor site has been decontaminated to acceptable residual radioactivity levels in accordance with LTP requirements for unrestricted use as specified in Subpart E, Radiological Criteria for License Termination, in 10 CFR 20, Standards for Protection Against Radiation.

• To verify that the licensees implementing procedures, radiological measurements, decommissioning surveys, and documentation of decommissioning surveys comply with the submitted or approved LTP.

• To conduct sufficient confirmatory or verification surveys so that NRC can verify and conclude that the licensees decommissioning activities and survey program have been implemented in a manner that provides confidence in the results that the site does not pose an undue risk to public health and safety.

3.2 Observations and Findings

a. Remediation Activities and Final Status Surveys (FSS)

The inspectors reviewed the LTP and the licensees procedures that govern performance of Remedial Action Support Surveys (RASS) and FSSs for the auxiliary building basement trenches, chain of custody, access control to FSS areas, survey data collection and data management, survey quality assurance requirements, and records retention requirements. The inspectors noted that the FSS was written in such a way as to detect Derived Concentration Guideline Levels (DCGLs) that were not concurrent with the NRC approved LTP, but rather the DCGLs contained within Technical Support Document (TSD) FC-24-004, DCGLs, Remediation Strategy and Survey Methodology for The Auxiliary Building East Trenches, revision 1, which are different from those in the LTP.

The inspectors reviewed the radiological instruments used to conduct the FSS of the auxiliary basement trenches to verify that the instruments were calibrated and appropriate to detect the radionuclides of concern (ROC). The licensee primarily used In-Sutu Object Counting which was appropriate and industry standard to detect the ROC action levels, DCGLs, and was sufficient to detect Minimum Detectable Concentrations (MDC) for action level concentrations both in the LTP and in TSD FC-24-004.

The inspectors reviewed the FSS data taken in the auxiliary basement trenches and noted that 2 sample locations exceeded the DCGLs for table 5-6 in the approved LTP for Cobalt-60 and 18 sample locations exceeded the DCGLs in table 5-6 in the approved LTP for Cesium-137. These results indicate that more remediation will be required by the licensee to meet the NRC approved DCGLs in the LTP. However, the licensee has generated the afore mentioned TSD FC-24-004 which details, in part, new DCGLs that account for filling the trenches with concrete grout. At the time of the inspection, the licensee was in the process of generating a licensee amendment request for NRC approval that will incorporate these new DCGLs into the LTP. The inspectors reviewed TSD FC-24-004 and compared the FSS results with the new DCGLs in the TSD FC-24-004 and noted they were all below the newly determined, but non-NRC approved, DCGLs.

b. Verification and Confirmatory Surveys

The NRC contracted Oak Ridge Associated University (ORAU) to develop and perform a comprehensive independent confirmatory survey such that the NRC can effectively assess the adequacy of the licensee's FSS results. The inspectors reviewed the MDC for instruments and select DCGL results of surveys that were performed by ORAU and did not note remarkable differences from the licensees collected data.

c. Problem Identification and Resolution

The inspectors reviewed select problems identified with FSS and RASS surveys, in part, for thoroughness of documentation and effectiveness of corrections. No significant findings were identified.

3.3 Conclusion

The licensees surveys which were validated by the NRCs contractor, show that the permanently shutdown power reactor site has not been decontaminated to acceptable residual radioactivity levels in accordance with the LTP.

4 Occupational Radiation Exposure at Permanently Shutdown Reactors (IP 83750)

4.1 Inspection Scope

The inspectors independently gathered sufficient information to determine whether licensee performance meets the following objectives:

• To ensure adequate protection of worker health and safety from exposure to radiation or radioactive material at permanently shutdown reactors.

• To evaluate whether the licensee adequately identifies problems and implements appropriate and timely corrective actions related to occupational radiation safety.

4.2 Observations and Findings a. Organization, Changes, and Training

The inspectors reviewed staffing for major changes since the last inspection in organization, personnel, facilities, radiation instrumentation, equipment, programs, and procedures that might affect occupational radiation protection. Noted changes included a shift in radiation protection personnel to the Final Status Survey group which would be expected for the decommissioning progress at the time.

The inspectors reviewed the education, experience, qualifications, and training of select members of the licensee's contracted Final Status Survey group. All parameters reviewed were noted to be adequate and up to date.

b. Radiological Work Planning and Observation

The inspectors conducted observations to verify the licensee was identifying the magnitude and extent of radiological hazards and was adequately assessing the radiological hazards and adequate worker radiation protection technician implementation of radiological controls. Specifically, the inspectors attended the pre-job brief and reviewed the associated procedure and radiological work permit for the preparation of the Mausoleum to receive steam generator assemblies.

The inspectors verified that the licensees planning and pre-job briefing for the Mausoleum work was commensurate with the risk of the work and identified appropriate dose reduction techniques, defined reasonable dose goals, and identified appropriate radiation protection hold or verification points as applicable.

The inspectors performed a tour of the radiological control area inside the containment structure to verify appropriate radiological postings, high radiation area and locked high radiation area controls, and evaluate material conditions. All areas were determined to be appropriately posted and controlled. Material condition was noted to be adequate.

c. Dosimetry The inspectors obtained the National Voluntary Laboratory Accreditation Program certification documentation for Landauer who processed the licensees personnel dosimeters and verified that the approved radiation test categories for each type of personnel dosimeter were consistent with the types and energies of radiation present, and method of dosimeter used.

The inspectors evaluated the onsite storage of dosimeters before their issuance, during use, and before processing/reading and noted that licensee processes were consistent with good radiation protection practices for accurate measurement of personnel dose received.

The inspectors interviewed dosimetry handling personnel as to how bias was determined to correct the response of the electronic alarming dosimeter as compared to passive dosimetry and that the correction factor was based on sound technical principles. The

inspectors evaluated, through direct observation, placement of whole-body dosimeters by site personnel actively using both passive and electronic alarming dosimetry and noted that good radiation protection practices were being followed.

The inspectors determined through interview there was one worker who had declared their pregnancy since the last inspection. The inspectors reviewed the monitoring controls employed by the licensee and varied the monitoring program to assess the dose to the embryo/fetus was adequate.

The inspectors reviewed select dose assessments to evaluate the licensees method for calculating shallow dose equivalent from distributed skin contamination and noted the licensees methodology to be adequate to accurately assign dose received.

d. Problem Identification and Resolution

The inspectors reviewed a sample of deficiencies documented in the CAP and verified that the licensee had identified and implemented appropriate corrective actions.

4.3 Conclusion

The licensee was ensuring adequate protection of worker health and safety from exposure to radiation or radioactive material. No significant findings were noted.

5 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors (IP 37801)

5.1 Inspection Scope The inspectors independently gathered sufficient information to determine whether licensee performance meets the following objectives:

• To verify the licensees safety review process is in accordance with the requirements of 10 CFR 50.59, Changes, tests, and experiments.

• To provide assurance that required license amendments have been obtained.

5.2 Observations and Findings

a. Decommissioning Safety Review Program

The inspectors reviewed the licensees safety review process and procedures, specifically FCSI-RA-203, 50.59 Review Process, revision 6 and FCSI-RA-203-1, 50.59 Resource Manual, revision 4. Additionally, select qualifications and training for personnel who to prepare, review, and approve safety evaluations were reviewed for adequacy.

It was noted by the inspectors through document review and interviews that cognizant licensee personnel were knowledgeable and appeared to be appropriately trained.

b. Design Changes, Tests, Experiments, and Modifications

No design changes, tests, experiments, or modifications requiring screening or review were conducted during the sample period from February 2023 to present.

No licensee safety review committee meetings were performed during the time of the inspection.

5.3 Conclusion

The licensee was prepared to implement the safety review program in accordance with site procedures and regulatory requirements. No findings of significance were identified.

6 Solid Radioactive Waste Management and Transportation of Radioactive Materials (IP 86750)

6.1 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 material.

6.2 Observations and Findings

The inspectors reviewed section 2.2 of the PSDAR which provides the licensees commitments for management and shipment of radioactive wastes. The inspectors reviewed the contractors waste management plan and associated implementing procedures, conducted site tours, and interviewed site staff to verify the effectiveness of the licensees waste management and shipment programs.

a. Radioactive Material Storage and Control

Procedure FCSD-RW-PG-100, Waste Management Program, revision 0, provided the overarching plan for onsite waste management and shipment activities. During site tours, the inspectors noted that the licensees contractor appeared to be effectively managing these waste streams.

Section 4.16 provided waste storage requirements. The inspectors randomly reviewed the storage of wastes at the site. The licensee and its contractor continued to maintain lists of storage locations and storage containers and conducted inspections of these containers at 2-year intervals. The waste storage areas were being managed in accordance with site procedures.

b. Radioactive Waste Processing

The licensees contractor was not processing wastes at the time of the inspection; therefore, this program area was not inspected.

c. Transportation of Radioactive Materials

The inspectors reviewed the applicable site procedure that provided details for shipment of radioactive materials. The inspectors compared the instructions provided in the implementing procedure to recently shipped items. Based on the contractors records, the two shipments were made in compliance with U.S. Department of Transportation (DOT) and procedural requirements.

The inspectors confirmed that both the licensee and its decommissioning contractor had established electronic databases to manage the training of workers involved in the handling and shipment of radioactive wastes. The inspectors reviewed the training of a waste broker and confirmed that the individual had been trained including completion of function-specific training required by DOT regulations.

d. Problem Identification and Resolution

The inspectors reviewed the status of the licensees and contractors CAP for entries involving waste management and transportation activities.

6.3 Conclusion The licensee and its decommissioning contractor conducted waste management and shipping activities in accordance with procedural instructions, PSDAR commitments, and regulatory requirements. No findings of significance were identified.

7 Exit Meeting Summary

The inspectors presented the final inspection results to the Chief Nuclear Officer/Vice President Decommissioning and other members of the licensees staff on May 9, 2024. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

SUPPLEMENTAL INSPECTION INFORMATION KEY POINTS OF CONTACT

Licensee and Contractor Personnel

A. Barker, Regulatory Assurance & Emergency Planning Manager K. Daughenbaugh, ISFSI Shift Supervisor J. Emich, Waste Project Manager, EnergySolutions C. Fellman, Senior Human Capital Business Partner A. Hansen, Principal Regulatory Specialist C. Heimes, Manager ISFSI Site Security A. Kodra, License Termination Plan/Final Status Survey Project Manager, EnergySolutions J. Layton, Supervisor Outage Planning & Scheduling T. Maine, Plant Manager J. McBride, Lead Nuclear Oversight T. Mountain, Waste Broker, EnergySolutions J. Nowak, Project Director, EnergySolutions B. Pearson, Supervisor Radiation Protection A. Staebell, Manager Maintenance Services D. Weaver, Manager Project Controls

INSPECTION PROCEDURES USED

IP 71801 Decommissioning Performance and Status Reviews at Permanently Shutdown Reactors

IP 40801 Problem Identification and Resolution at Permanently Shutdown Reactors

IP 83801 Inspection of Remedial and Final Surveys at Permanently Shutdown Reactors

IP 83750 Occupational Radiation Exposure at Permanently Shutdown Reactors

IP 37801 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors

IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials

LIST OF ACRONYMS

ADAMS Agencywide Documents Access and Management System CAP Corrective Action Program CFR Code of Federal Regulations DCGLs Derived Concentration Guideline Levels DOT Department of Transportation DQAP Decommissioning Quality Assurance Program FSS Final Status Survey IP Inspection Procedure LTP License Termination Plan MDC Minimum Detectable Concentrations NRC Nuclear Regulatory Commission ORAU Oak Ridge Associated University PSDAR Post-Shutdown Decommissioning Activities Report QA Quality Assurance RASS Remedial Action Support Surveys ROC Radionuclide of Concern TSD Technical Support Document

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