IR 05000293/2020004

NRC Inspection Report No. 05000293/2020004, Holtec Decommissioning International, LLC, Pilgrim Nuclear Power Station, Plymouth, Massachusetts

ML21053A315
Person / Time
Site:	Pilgrim
Issue date:	02/22/2021
From:	Anthony Dimitriadis Decommissioning Branch I
To:	Cowan P Holtec Decommissioning International
References
IR 2020004
Download: ML21053A315 (9)

Text

February 22, 2021

SUBJECT:

NRC INSPECTION REPORT NO. 05000293/2020004, HOLTEC DECOMMISSIONING INTERNATIONAL, LLC, PILGRIM NUCLEAR POWER STATION, PLYMOUTH, MASSACHUSETTS

Dear Ms. Cowan:

On December 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection under Inspection Manual Chapter 2561, Decommissioning Power Reactor Inspection Program," at the permanently shutdown Pilgrim Nuclear Power Station (PNPS).

Focused topical inspections using two inspection procedures were also conducted on November 9 - 13, 2020. These were done remotely, as a consequence of the COVID-19 public health emergency (PHE). The inspector 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 inspector (via remote means), interviews with site personnel, and a review of procedures and records. The results of the inspection were discussed with Mr. Joseph McDonough, Senior Manager for Operations, and other members of the PNPS staff on January 27, 2021, and are described in the enclosed report. No findings of significance were identified.

In accordance with 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.

Current NRC regulations and guidance are included on the NRC's website at www.nrc.gov; select Radioactive Waste; Decommissioning of Nuclear Facilities; then Regulations, Guidance and Communications. The current Enforcement Policy is included on the NRC's Website at www.nrc.gov; select About NRC, Organizations & Functions; Office of Enforcement; Enforcement documents; then Enforcement Policy (Under 'Related Information'). You may also obtain these documents by contacting the Government Printing Office (GPO) toll-free at 1-866-512-1800. The GPO is open from 8:00 a.m. to 5:30 p.m. EST, Monday through Friday (except Federal holidays). No reply to this letter is required. Please contact Harold (Harry) Anagnostopoulos at 610-337-5322 if you have any questions regarding this matter.

Sincerely,

/RA/

Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Nuclear Materials Safety Docket No. 05000293 License No. DPR-35 Enclosure: Inspection Report 05000293/2020004 w/Attachment cc w/encl: Distribution via ListServ

EXECUTIVE SUMMARY

Holtec Decommissioning International, LLC (HDI)

Pilgrim Nuclear Power Station (PNPS)

NRC Inspection Report No. 05000293/2020004 An announced decommissioning inspection was completed on December 31, 2020 for the Pilgrim Nuclear Power Station (PNPS). A focused topical inspection using two inspection procedures was conducted on November 9 - 13, 2020. This focused inspection activity was performed remotely as a consequence of the COVID-19 public health emergency (PHE). The inspection included a review of radioactive waste handling and storage, radioactive material shipping, radioactive effluent monitoring and reporting, environmental monitoring and reporting, and groundwater protection initiative monitoring. The inspector also examined the preparations for removal of the main plant effluent stack and segmentation of the dryer/separator.

The inspections consisted of observations by the inspectors, interviews with PNPS personnel, a review of procedures and records, and observations of activities via teleconference and shared images. The U.S Nuclear Regulatory Commissions (NRC's) program for overseeing the safe operation 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 findings of safety significance were identified.

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REPORT DETAILS

1.0 Background June 10, 2019, Entergy Nuclear Operations, Inc. (ENOI) certified cessation of power operations and the permanent removal of fuel from the PNPS reactor vessel (ADAMS Accession Number: ML19161A033). This met the requirements of 10 Code of Federal Regulations (CFR) 50.82(a)(1)(i) and 50.82(a)(1)(ii). On June 11, 2019, the NRC notified PNPS that the NRC would no longer perform its oversight activities in accordance with the Operating Reactor Assessment Program and that oversight would be conducted under the provisions outlined in IMC 2561 Decommissioning Power Reactor Inspection Program (ADAMS Accession No. ML19162A033). On August 27, 2019 an amendment was issued transferring the license from ENOI to Holtec International, LLC HDI (ADAMS Accession No. ML19235A050). PNPS is in the active decommissioning phase with fuel in the spent fuel pool as described in IMC 2561.

2.0 Decommissioning Performance and Status Review

a. Inspection Scope

[Inspection Procedures 40801, 71801, 84750, and 86750]

In-office reviews of information supplied by PNPS were performed during the inspection period. The inspector reviewed corrective action program issue reports (IRs) routinely throughout the inspection period and followed-up with questions or requests for additional information as appropriate. The inspector attended routine weekly Holtec-NRC update meetings and monthly Holtec corporate project status meetings via remote means (teleconference).

The inspector reviewed the Annual Radiological Environmental Operating Report and the Annual Radioactive Effluent Release Report for 2019. The inspector reviewed changes to the placement of environmental dosimeters and environmental air samplers, as a result of the decommissioning status of the site.

The inspector reviewed the most recent results of the groundwater protection initiative monitoring program, and the proposed changes to the sampling frequencies, based upon the decommissioning status of the site.

The inspector reviewed the training and qualifications for persons who are certified to ship radioactive materials over public highways, reviewed the radioactive material shipping logs, and selected a sampling of shipping packages for a detailed inspection.

The inspector reviewed the most recent calibrations and evaluated the basis for the current setpoints of the reactor building vent radiation monitor and the liquid waste discharge radiation monitor.

The inspector reviewed the Holtec wet handling method for packaging and moving Class A wastes and for Class B/C wastes, including a review of drawings and procedures. The inspector reviewed photographs of the temporary Class B/C waste storage vaults while under construction and discussed access control procedures with radiation protection staff. The inspector reviewed site plans for the storage of radioactive materials that will be generated by upcoming decommissioning activities and also reviewed the results of routine radioactive waste container inspections.

Inspection Report No. 05000293/2020004

The inspector reviewed vendor technical documents used by Holtec to characterize the wastes generated by cutting the steam dryer and steam separator in the reactor cavity, and to estimate the dose rates on those items after cutting. The inspector attended a routine pre-job briefing, via teleconference, for cutting the steam dryer and reviewed the results of routine chemistry and radiological sampling of the water in the reactor cavity/

dryer-separator pit. Additionally, the inspector reviewed plans for removal of the main plant effluent stack, including the radiological survey plan and the results of investigational radiological surveys.

The inspector reviewed a quality assurance audit of the Chemistry, Environmental, Radiation Protection, and Radioactive Waste functional area. Additionally, the inspector reviewed any significant changes to the Offsite Dose Calculation Manual, and the Process Control Program since the last inspection.

b. Observations and Findings

The inspector determined that a technical evaluation for the suspension of radioiodine sampling at environmental air sampling stations followed a rigorous technical approach, and appropriately reflected the decommissioning status of the site. The inspector determined that changes to the Radiological Environmental Monitoring Program (REMP)and the Groundwater Protection Initiative (GPI) were reasonable and appropriately reflected the decommissioning status of the site.

The inspector determined that the access control procedures for the temporary Class B/C waste storage vaults were detailed and reflected the significance of the potential radiological hazard. The inspector identified several data reporting errors in the 2019 Annual Radiological Environmental Operating Report. Upon identification, Holtec wrote an issue report to document the concern and initiate a correction of the errors. The errors were not significant to any conclusions in the report.

The inspector questioned the methods being used to establish the trip and alarm setpoints for the Reactor Building Ventilation radiation monitor and the Liquid Waste Effluent radiation monitor at Pilgrim following permanent shutdown and the significant change in the radiological source-term. Holtec provided a detailed technical evaluation during the inspection period and wrote an issue report to document and track the planned changes to the setpoint methodology. Although the trip and alarm setpoints methods should be adjusted, they were (and remain) protective of the public health and the environment.

c. Conclusions

Based on the results of this inspection, no findings of significance were identified.

3.0

Exit Meeting Summary

On January 27, 2021, the inspector presented the inspection results to Mr. Joseph McDonough, Senior Manager for Operations, and other members of the HDI staff. No proprietary information was retained by the inspector or documented in this report.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

Inspection Report No. 05000293/2020004

SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

J. Moylan, Site Vice President

J. McDonough, Operations Manager

D. Noyes, Senior Compliance Manager

L. Hageman, Senior HP/Chemistry Specialist

M. Lawson, Radiation Protection Manager

F. McGinnis, Regulatory Assurance Specialist

M. Thornhill, Certified Health Physicist

ITEMS OPEN, CLOSED, AND DISCUSSED

None

LIST OF DOCUMENTS REVIEWED

10CFR Part 61 Waste Stream Sample Screening and Evaluation, 2019 Bead Resin, dated

8/23/2019.

Annual Radioactive Effluent Release Report, 2019, dated 5/7/2020

Annual Radiological Environmental Operating Report, 2019, dated 5/7/2020

Calibration, RM 1705-30, dated 6/29/2019

Calibration, RM-1705-32A, dated 7/28/2020

Issue Report PIL-IR-0750, 0751, 0753, 0754, 0764, 0910, 0911, 1062, 1075, 1137, 1172,

203,1204,1205, 1287

Letter, Evaluation of Technical Basis for Termination of Radioiodine Sampling and Analysis,

dated 1/31/2020

Logbook, RP Supervisors, A Waste Basket ID#1016 Removal from the DSP, dated 12/1/2020

Logs, radioactive waste shipments for 2020

Offsite Dose Calculation Manual, PNPS-ODCM, Revision 14

Operator Aid #40, Process Radiation Monitor EPIC Alarm and ODCM Setpoints, dated

4/13/2001

P-EN-RP-2, Radioactive Shipping Procedure, Revision 18

P-EN-RW-101, Radioactive Waste Management, Revision 4

P-EN-RW-103, Radioactive Waste Tracking Procedure, Revision 5

P-EN-RW-105, Process Control Program, Revision 6

PNPS Groundwater Tritium Results, spreadsheet, through 9/3/2020

PNPS Post-Shutdown Groundwater Sample Frequencies, dated 7/23/2019

Presentation, B/C Waste Overview

Procedure 7.4.63, Process Radiation Monitor Setpoints, Revision 14

QA-2/6/14/15-2019-PNP-01, Audit of Chemistry, Environmental, Radiation Protection,

Radioactive Waste, dated 3/19/2020

Radiological survey 2020-0772

REE# 19-039, Free-Release Plan for the Main Stack, Revision 0

REE# 20-044, Technical Basis for Plant-Installed RMS Operation, Revision 0

Shipping packages RSR 20-001, 102, 104, 334, 356

Inspection Report No. 05000293/2020004

LIST OF ACRONYMS USED

ADAMS Agencywide Document and Access Management System

ENOI Entergy Nuclear Operations, Inc

HDI Holtec Decommissioning International, LLC

IMC Inspection Manual Chapter

IP Inspection Procedure

IR Issue Report

NRC U.S. Nuclear Regulatory Commission

PNPS Pilgrim Nuclear Power Station

Inspection Report No. 05000293/2020004