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Ni acti y 612 EAST LAMAR BLVD, SUITE 400
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March 30, 2011
Mr. Richard B. Provencher, Manager
Department of Energy
Idaho Operations Office
1955 Fremont Ave., MS 1203
Idaho Falls, ID 83415
SUBJECT: NRC INSPECTION REPORT 072-009/2011-001
Dear Mr. Provencher:
A routine inspection of spent fuel storage activities at the U.S. Department of Energy's Fort
Saint Vrain Independent Spent Fuel Storage Installation (ISFSI) was conducted on March 8-9,
2011. At the conclusion of the inspection on March 9, 2011, an exit briefing was conducted with
members of your staff. The enclosed report presents the scope and results of the nonsecurity
portion of this inspection. A second inspection report issued March 21, 2011, and not publicly
available, presented the security findings of this inspection.
The nonsecurity portion of this inspection examined activities conducted under your license as
they related to safety and compliance with the Commission's rules and regulations and with the
conditions of your license. Within these areas, the inspection included reviews of the ISFSI
emergency response program, training, radiation protection, environmental monitoring,
operations, organization, quality assurance, corrective action program, aging management, and
safety reviews conducted by your staff. No findings of significance were identified.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosures, and your response (if any) will be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records (PARS) component of
NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). 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.
Should you have any questions concerning this inspection, please contact the undersigned at
817-860-8191 or Mr. Lee Brookhart at 817-276-6549.
Sincerely,
441)4
D. Blair Spitzberg, PhD, Chief
Repository & Spent Fuel Safety Branch
Docket: 072-009
License: SNM-2504
CrrcveAVAx iD h S
- 11- 1 1 2011-0928
Department of Energy - 2 -
Enclosure:
NRC Inspection Report 072-009/2011-01
w/attachment
cc w/enclosure:
Kenneth R. Whitham Director
NRC Licensing Manager Laboratory & Radiation Services Division
U.S. Department of Energy, Colorado Department of Public Health
Idaho Operations Office and Environment
1955 Fremont Ave., MS-5121 8100 Lowry Boulevard
Idaho Falls, ID 83402 Denver, CO 80230-6928
Bradley J. Davis
Licensed Facility Director
U.S. Department of Energy,
Idaho Operations Office
1955 Fremont Ave., MS-5121
Idaho Falls, ID 83402
Donald A. Armour
Quality Assurance Manager
U.S. Department of Energy,
Idaho Operations Office
1955 Fremont Ave., MS-5121
Idaho Falls, ID 83402
Mr. Charlie Bomberger
XCEL Energy
414 Nicollet Mall
RCQ 8
Minneapolis, MN 55401
Chairman
Board of County Commissioners
Of Weld County, Colorado
915 10th Street
Greely, CO 80631
Regional Representative
Radiations Programs
Environmental Protection Agency
1 Denver Place
999 18th Street, Suite 1300
Denver, CO 80202-2413
•
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 072-009
License: SNM-2504
Report: 072-009/2011-001
Licensee: United States Department of Energy
Facility: Fort St. Vrain Independent Spent Fuel Storage Installation
Location: 16805 Weld County Road 19-1/2
Platteville, CO 80651
Dates: March 8-9, 2011
Inspectors: Vincent Everett, Senior Inspector
Repository & Spent Fuel Safety Branch
Lee Brookhart, Health Physicist
Repository & Spent Fuel Safety Branch
Accompanied By: Chris Staab, Project Manager
Spent Fuel Storage and Transportation
Jean Trefethen, Project Manager
Environmental Protection and Performance Assessment
Approved By: D. Blair Spitzberg, PhD., Chief
Repository & Spent Fuel Safety Branch
Attachment: Supplemental Inspection Information
ENCLOSURE
EXECUTIVE SUMMARY
United States Department of Energy
NRC Inspection Report 072-09/11-01
The U.S. Department of Energy (DOE) was licensed by the U.S. Nuclear Regulatory
Commission (NRC) to operate the Fort St. Vrain Independent Spent Fuel Storage Installation
(ISFSI) located near Platteville, Colorado. The facility was being maintained by CH2M-WG
Idaho, LLC (CWI) as the management and operations contractor for DOE.
Away from Reactor ISFSI Inspection Guidance (60858)
• The ISFSI facility was being maintained in good physical condition with no observable
deterioration. Radiological areas inside the facility were properly posted (Section 1.2.a).
• The emergency planning program was being maintained current. Drills, exercises, and
training were performed in accordance with requirements in the emergency plan. Training
and participation in drills/exercises were offered to offsite support agencies. Changes to the
emergency plan since the last NRC inspection were reviewed to verify that the effectiveness
of the plan was not reduced (Section 1.2.b).
• Radiological conditions at the facility had not changed since the last inspection.
Radiological surveys and contamination surveys were conducted in accordance with the
licensee's procedures. No abnormal conditions were identified (Section 1.2.c).
• The site environmental radiation protection program was being implemented to verify
radiation conditions at the ISFSI were in compliance with NRC radiation standards.
Environmental dosimeters were adequately located around the ISFSI to demonstrate
compliance with exposure limits to the public (Section 1.2.d).
• Biennial reports were sent to the NRC in accordance with 72.48(d)(2). Revisions to the
Safety Analysis Report (SAR) and Technical Specifications since February 2006 were
acceptable and within the requirements of the 72.48 process (Section 1.2.e).
• Operational activities associated with inspection of cooling inlet and outlet screens,
performance of fuel storage container leak tests on a 5-year frequency, and checks of the
crane's seismic restraints had been conducted in accordance with the requirements of the
Technical Specifications (Section 1.2.p.
• The ISFSI organization was in compliance with SAR requirements for staffing and
qualifications of personnel. Training was being performed and documented for site
personnel to meet the requirements of the SAR. The Safety Review Committee had met on
an annual bases and reviewed issues consistent with requirements in the SAR and
Technical Specifications (Section 1.2.g).
• The Quality Assurance organization had performed two audits annually with approximately
10 surveillances annually since the last inspection of February 2006. The ISFSI program
elements reviewed had been described as effective. Identified deficiencies had been
entered into the licensee's corrective action system (Section 1.2.h).
- 2 - ENCLOSURE
• The corrective action system was being used to capture issues and document corrective
actions. All deficiency reports (DRs) reviewed had been adequately resolved. No adverse
trends were identified (Section 1.2.i).
• An aging management program was developed as part of the 20-year license extension
application. The licensee evaluated the important to safety aspects of the ISFSI and
systematically reviewed the potential areas in which periodic surveillances should be
performed to identify age related degradation issues over the next licensed period of the
facility. The primary area identified for additional observation was the condition of the
concrete structures (Section 1.2.j).
Review of 10 CFR 72.48 Evaluations (60857)
• All safety screenings and evaluations had been performed in accordance with facility
procedures and 10 CFR 72.48 requirements by qualified personnel (Section 2.2).
- 3 - ENCLOSURE
Report Details
Summary of Facility Status
The Fort St. Vrain Independent Spent Fuel Storage Installation (ISFSI) is a modular vault dry
storage (MVDS) system developed by Foster Wheeler Energy Corporation. The facility
provided storage for the spent fuel from the decommissioned Fort St. Vrain high temperature
gas cooled reactor. There were 244 fuel storage containers loaded with spent fuel at the Fort
St. Vrain ISFSI.
The Fort St. Vrain ISFSI license was transferred from Public Service Company of Colorado to
the Department of Energy (DOE) on June 4, 1999. The facility was being maintained by CH2M-
WG Idaho, LLC (CWI) as the management and operations contractor for the DOE. A tour of the
ISFSI area and review of site records found the facility to be in good physical condition.
Radiation levels were within acceptable levels, consistent with past dose rates at the facility.
The CWI and DOE staff have continued to maintain the spent fuel in a safe configuration and
have established, through a strong procedural and quality assurance process, the necessary
documentation and records that confirm compliance with NRC regulations and the site license.
1 Away from Reactor ISFSI Inspection Guidance (60858)
1.1 Inspection Scope
The ISFSI inspection included review of selected records and interviews with site
personnel to verify ISFSI operations were in compliance with the Fort St. Vrain License
SNM-2504 certificate of compliance and Technical Specifications, Amendment 9, and
the Safety Analysis Report, Revision 9. A tour of the ISFSI was conducted to confirm
the facility was being maintained in good physical condition for the safe storage of the
spent fuel. The Fort St. Vrain ISFSI operational inspection reviewed selected aspects of
the emergency response program, training, radiation protection, environmental
monitoring, operations, organization, quality assurance, corrective action program, and
aging management.
1.2 Observations and Findings
a. Site Tour of the ISFSI
A tour of the ISFSI was conducted to observe the general condition of the facility. The
deterioration
structure was in good physical condition with no observable deterioration l of the facility.
The facility was being well maintained, including the general area outside the ISFSI
building. The inlet and outlet screens were clear of any debris. The interior of the ISFSI
was clean and well kept. A seismic monitor was positioned on the floor of the truck bay.
Radiation levels were measured by inspectors during the tour. The background
radiation levels outside the facility were 15 - 20 µR/hr (0.015-0.020 mR/hr). This level
was similar to readings taken at the Denver airport area of 19 µR/hr. Radiation levels
inside the truck bay were 15—21 µR/hr. With the detector held against the truck bay
wall that provided shielding from the stored spent fuel, the reading on the wall was
50 µR/hr. Upstairs on the charge face, the readings ranged from 11 - 35 µR/hr. The
door to the charge face was posted as a radioactive materials area. Inside the charge
face area was a source storage cabinet containing check sources of Cs-137, AmBe, and
Tc-99. The source cabinet was roped off and posted as "Radiation Area, Neutron, and
- 4 - ENCLOSURE
Radiation Work Procedure (RWP) Required Entry." The reading at the roped off area
was 90 pR/hr. A depleted uranium plug was stored on the charge face and was posted
as radioactive material. In the far corner of the ISFSI were more depleted uranium plugs
that were roped off and posted as a radiation area. The reading at the rope of the
posted area was 33 pR/hr. Security tamper seals on the charge face were verified to
have been intact. The fuel handling machine was verified to have been properly stored.
b. Emergency Planning
Revisions to the licensee's emergency planning program since the last NRC inspection
in February 2006 were reviewed. The licensee's emergency plan, PLN-143, had been
revised six times during that time period. Revisions 8-13 were reviewed to verify that the
effectiveness of the plan was not reduced.
Required emergency plan drills/exercises were listed in Section 6.6.1.2 of the
emergency plan. Required semiannually drills included radiological/health physics drills,
medical drills, and fire drills. Biennial exercises were larger drills that tested the
adequacy of the implementing plan procedures, emergency equipment, and
communications networks and ensured the emergency response personnel were familiar
with their duties. Offsite response organizations were invited to participate in the
biennial exercises. The licensee had successfully conducted the required exercises
since the last ISFSI inspection. Drill packages for the medical drill of February 2008, a
natural phenomena drill of April 2008, the security drill of January 2009, the
radiological/health physics drill of March 2009, and a fire drill of May 2009 were selected
for review. The biennial exercises for 2006, 2008, and 2010 were selected for review.
The selected drills and exercises met the objectives of site Emergency Plan
Section 6.6.1.2. The drill and exercise packages included a description of the drill that
was conducted, a timeline, a synopsis, and a drill critique. Drill deficiencies and areas
for improvement were identified and placed into the licensee's corrective action program
for resolution. Offsite support agencies that participated in the different drills and/or
exercises included the Platteville/Gilcrest Fire Protection District, the Milliken Police
Department, the Milliken Fire Department, the Weld County Office of Emergency
Management, the Weld County Paramedic Service, the Weld County Regional
Communications Center, the Weld County Regional Sheriff's Center, and the North
Colorado Medical Center.
Emergency Plan Section 6.6.1.3 required semiannual verification of offsite agencies'
phone numbers. Procedure EPI-108, "Requirements of Fort St. Vrain Emergency
Rebpuu IJC Plan," Revision 8, Section 4.1.1, required verification of offsite telephone
numbers. The licensee's phone list, LST-26, "INL Emergency Telephone Numbers,"
listed the agencies that were required to be contacted. The semiannual phone
verification for the year 2010 was reviewed. Both required semiannual phone
verifications were performed as required.
A review of the emergency response personnel training records was conducted to verify
that the licensee's emergency response organization was currently qualified. An
employee qualification report dated March 9, 2011, documented that all emergency
response personnel were current on their qualifications. For the Fort St. Vrain ISFSI, the
on-shift security officer does not make the emergency classification. The security officer
calls one of the facility management personnel and reports the situation. The
management personnel then makes the emergency classification determination. Once
- 5 - ENCLOSURE
classified, Idaho National Laboratory (INL) is notified and Idaho makes the calls to the
offsite agencies. The facility management personnel or INL would make the call to the
NRC. The on-shift security officer would call 911 for immediate response. A copy of the
current emergency planning procedures was in the cabinet next to the on-shift security
officer.
The annually required review of the licensee's memorandums of understanding (MOU)
with offsite response agencies per Section 6.6.2.3 of their emergency plan was
performed. Years 2009 and 2010 were selected for compliance with the requirement.
The licensee provided an interoffice memorandum that documented that the annual
reviews were performed and all MOUs with offsite response organizations were still
current. The offsite response organization's MOUs reviewed matched the offsite liaisons
listed in Section 9.1.5 of the Final Safety Analysis Report.
The licensee's emergency plan was verified to have provisions for notifying the NRC of
emergencies as required by 10 CFR 72.75. This was incorporated into Procedure
EPI-103, "Event Notifications for Fort Saint Vrain," Revision 18. Section 4.1.1.2.2 of the
procedure required notification to the NRC Operations Center as soon as possible but
no longer than 1 hour after declaration of an emergency event classification, consistent
with §72.75(a). Section 4.2.2.2 required notification to the NRC Operation Center within
4 hours of a nonemergency event consistent with §72.75(b). The reporting requirements
of §72.75(d) for a 24-hour report and §72.75(g) for a 60-day report to the NRC was
specified in Procedure MCP-2924, "NRC Licensee Event and Condition Reporting," in
Sections 4.2.1 and 4.4.1, respectively. Procedure MCP-2924 also included reporting
requirements to the NRC from the requirements listed in the Technical Specifications,
10 CFR Part 20, 10 CFR Part 21, and 10 CFR Part 73.
c. Radiation Protection
Radiological conditions at the facility had not changed since the last inspection.
Radiological surveys and contamination surveys were conducted in accordance with
Procedure MCP-139, "Radiological Surveys," Revision 14, and Procedure PRD-317,
"Radiation Protection, Safety and Health and Environmental Protection Programs for
NRC Regulated Facilities," Revision 8. Procedure PRD-317, Appendix D, "Fort St. Vrain
ISFSI Radiological Survey Report," provided the forms used by the licensee to document
the surveys. Surveys were conducted using an Eberline 177L survey instrument.
Selected quarterly radiological surveys performed between November 28, 2006, and
April 29, 2010, were reviewed. Radiological survey results outside the ISFSI building
and on the charge face were less than the minimum detection limits of the survey
instrument, 0.2 mR/hr. Contamination surveys found no contamination above
background.
Semiannual leak tests of the sources kept in the source storage cabinet were performed
using Procedure MCP-137, "Radioactive Source Accountability and Control,"
Revision 13. Section 4.6.4, "Inventory," and Section 4.6.5, "Source Leak Testing,"
provided information related to the semiannual inventory and leak test. Semiannual leak
tests and inventory of the 840 mCi AmBe source were reviewed for July 2009, January
2010, July 2010, and January 2011. No leaks were detected. The three Cs-137
sources and the Tc-99 source were exempt from the accountability and leak test
requirements. Section 5 of Procedure MCP-137 defined accountable sealed radioactive
sources as those having a half-life equal to or greater than 30 days and an isotopic
- 6 - ENCLOSURE
activity equal to or greater than the corresponding value provided in 10 CFR Part 835,
Appendix E, dated June 8, 2007. The three Cs- 137 sources had activities of 24.1 pCi,
4.53 pCi and 1 pCi. The value from Appendix E of 10 CFR Part 835 for Cs-137 was 60
pCi. For the Tc-99 source, the source strength was 24,605 disintegrations/minute (dpm)
which equated to approximately 0.01 pCi. The Appendix E value for Tc-99 was 25 pCi.
The quarterly sampling of the vault drain system was performed using Procedure
TPR-5613, "Fort St. Vrain ISFSI Radiation Survey and Vault Drain System Sample
Collection and Analysis," Revision 7. Eight quarterly sampling results were reviewed
from November 28, 2006, through April 29, 2010. No liquids were found in the vault
drain line during any sampling.
Personnel at the Fort St. Vrain ISFSI were not assigned radiation dosimetry because
radiation levels were at background levels for all accessible areas, except around the
posted radiation sources. Expected personnel exposures were below the 10 percent
annual limit of exposure specified in 10 CFR 20.1201 and, as such, personnel were not
required to wear dosimetry per 10 CFR 20.1502. Expected exposure levels were based
on radiological surveys. Approximately 12 thermoluminescent dosimeters (TLDs) were
stored at the site to be available if needed.
d. Annual Radiological Environmental Monitoring Report
The annual radiological environmental monitoring reports since the last NRC inspection
were reviewed to confirm that environmental conditions at the ISFSI had remained
stable since the last inspection. The licensee was required by Technical
Specification 5.5.4(c) to submit an annual report to the NRC within 60 days after
January 1 of each year. Five reports had been submitted since the last inspection,
including the 2006 report dated February 26, 2007 (ML070650337), the 2007 report
dated February 20, 2008 (ML080590359), the 2008 report dated February 11, 2009
(ML090560534), the 2009 report dated February 16, 2010 (ML100550053), and the
2010 report dated February 14, 2011 (ML110540307). The environmental monitoring
program at Fort St. Vrain consisted of 20 TLDs located on a 100-meter perimeter fence
around the ISFSI. A control TLD was located at the Weld County Sheriff's office in
Greeley, Colorado, approximately 17 miles NNE of the ISFSI. One third of the TLDs
were collected and processed monthly and replaced with new TLDs. The control TLD
was also processed and replaced monthly.
The following table provides the annual average exposure rates reported in the annual
environmental monitoring reports:
YEAR MEAN (mR/day) CONTROL
(mR/day)
2006 0.37 +/- 0.04 0.34 +/- 0.03
2007 0.37 +/- 0.08 0.36 +/- 0.09
2008 0.38 +/- 0.03 0.35 +/- 0.04
2009 0.40 +/- 0.08 0.37 +/- 0.10
2010 0.39 +/- 0.03 0.36 +/- 0.02
- 7 - ENCLOSURE
The environmental data was consistent with data that had been collected in the past at
the Fort St. Vrain site and was statistically within the background levels measured by the
controls. There were no radioactive liquids released from the facility.
During 2009, TLDs collected for March had unusually high readings ( 0.65 mR/day),
whereas the samples collected for April had unusually low readings (0.24 mR/day)
compared to the mean for the year of 0.40 mR/day. The higher March readings were
attributed to exposure while in transient based on the control dosimeter used during
shipment. However, the low April readings could not be explained. The licensee
initiated Work Group Task #21972 to evaluate the issue. Preliminary indication was a
problem had occurred with how the values on the control dosimeters were assigned to
the 2 months.
e. Biennial Update Reports and SAR Revisions
Biennial reports for the period from June 2005 through June 2009 were reviewed. This
period was covered by two reports dated May 29, 2007 (ML071580197), and June 4,
2009 (ML091950422). These reports provided information related to revisions during
the reporting period to the SAR and certain programs required by the Technical
Specifications. The biennial reports also discussed any safety evaluations performed.
Issuance of the May 29, 2007, biennial report included Revision 6 to the SAR.
Revision 6 changes primarily related to the DOE organization titles and responsibilities in
Chapter 9, "Conduct of Operations," and Chapter 11, "Quality Assurance." During this
2-year period, no changes were made to the facility pursuant to 10 CFR 72.48, to the
Technical Specification bases, or to the radiological environmental monitoring program.
Editorial changes were made to the training program. Changes were made to the
Quality Assurance Program described in Chapter 11 of the SAR to describe the new
DOE organization and to identify that contractor stop work authority resided with the
INTEC Quality Assurance Manager. Stop work authority did continue to remain granted
in Section 7.6.1 of the latest revision (Revision 9) of the SAR to any individual who
observed an actual or potential unsafe radiological condition.
Several new gas wells were added to the area around Fort St. Vrain. Technical
Specification 5.5.3 required a database be maintained of all natural gas and oil
infrastructures within % mile of the ISFSI. If a new facility posed a new hazard not
already analyzed, then a report to the NRC was required. DOE identified four new
natural gas wells, one located within the 1/2-mile boundary and three just outside the
boundary. Ail four tied into existing production equipment and were bounded by hazards
analysis previously performed for the site.
The June 4, 2009, biennial report included Revision 7 of the SAR. Changes were made
to nearly every chapter in the SAR. The licensee identified most of these changes as
being editorial. However, several sections were identified as having changes more than
just editorial: Chapters 1 and 2 were updated to include the 2000 census numbers,
replacing the 1980 values. Chapters 3 and 4 were revised to move the sections
"Classification of Structures, Components and Systems" and "Decommissioning
Considerations" from Chapter 4 to Chapter 3 and to remove several items from the list of
items important to safety. The individual fuel element grapple, the transfer cask, and the
neutron source storage wells were removed from the list. Since the ISFSI was not
licensed to handle individual fuel elements and the fuel was contained in fuel storage
- 8 - ENCLOSURE
containers which would be lifted by the container handling machine fuel storage
container grapple, the individual fuel element grapple was not needed. The fuel storage
container grapple was currently included on the list of items important to safety. The
transfer casks had been included in the original license and were used to transfer the
fuel elements from the Fort St. Vrain reactor facility to the ISFSI, but have since been
replaced by the TN-FSV casks that have current 10 CFR Part 71 licensees. The neutron
storage wells were originally designed to hold the six neutron source fuel elements
containing the Californium-252 neutron sources. But the Cf-252 was removed from the
fuel elements prior to placement of the fuel elements in the ISFSI. The neutron source
storage wells were identical in design to the standby storage wells (SSW) and as such
have been re-designated by the licensee as SSWs. Revision 6 to the SAR had listed
"Standby and neutron source storage wells" in Table 4.5-1, "Fort St. Vrain ISFSI
Components Classified as Important to Safety." Revision 7 changed the wording to
"Standby storage wells." Revision 7 also moved the table to Chapter 3 as Table 3.4-1.
Changes were made to SAR Chapter 9.2, "Preoperational Testing Activities," to remove
outdated information related to the transition of the ISFSI from Public Service of
Colorado to DOE. The revised chapter focused on preoperational activities required for
moving fuel. An update was made to the natural gas and oil data base to add two gas
wells. Also during this reporting period an expansion to increase the generating capacity
of the Fort St. Vrain natural gas generating facility, located adjacent to the
decommissioned reactor facility, was approved by the regulatory agencies. Two
additional natural gas combustion turbines, a new gas supply line, and a gas facility
were part of the expansion. An evaluation conducted by the licensee determined that
the new expansion was bounded by the current safety analysis and did not present a
new or unanalyzed risk to the ISFSI.
Since issuance of the June 4, 2009, biennial update report, two revisions have been
made to the SAR. Both revisions were in support of the application for a license
extension for the Fort St. Vrain facility. On August 13, 2010, Revision 8 of the SAR was
issued. The primary change was to add a new Section 9.8, "Aging Management
Program." The aging management program included visual inspections of the
accessible concrete and any exposed steel embedments and attachments. It also
included monitoring the area radiation and loose surface contamination levels at
selected areas of the ISFSI. Procedures were revised to increase inspection
frequencies and perform tracking and trending of aging conditions.
The second SAR revision was described in a letter to the NRC dated November 30,
/� n_..:..:__ 01111 added
L-
201U. Revision 9 to the SAR aUUCU a requirement to the aglllg II Id!1GyCIIICIIt prVgralll
described in Section 9.8 to conduct a visual inspection of the vault internals every
10 years.
f. Technical Specification Compliance and SAR Requirements
Technical Specification 3.3.1 required the licensee to conduct a leak test of one fuel
storage container from each vault every 5 years. The leak rate limit for the seals was
1 x 10-3 standard cubic centimeters per second (cc/sec). The previous leak testing was
completed September 2005 and documented in the last NRC inspection report 72-09/05-
01 (ML060460621) dated February 15, 2006.
- 9 - ENCLOSURE
The 2010 leak tests were conducted using Procedure TPR-5604, "Fort St. Vrain ISFSI
Fuel Storage Container O-Ring Vacuum Leak Test," Revision 16. The leak tests were
performed by a qualified examiner certified as a Level II NDE Leak Test Examiner. The
Fort St. Vrain ISFSI certified fuel handlers, facility safety officer, and the Fort St. Vrain
ISFSI Manager assisted with the testing.
New leak test equipment was used in 2010 from that previously used in 2005. Leak
testing was performed manually using hand operated valves and a manually read
pressure indicator connected to the lid seal interface connection port. The test volume
was evacuated to a pressure of approximately 100 milliTorr and isolated; then a timed
pressure rise test was performed to determine a leak rate. Leak tests were performed
on six fuel storage container lid seats (one for each vault) and on three standby storage
well (SSW) lid seals.
The leak tests were conducted during the week of June 21, 2010. The leakage test
results were all less than the allowable rate of 1.0 x 10-3 cc/sec as specified in Technical
Specification 3.3.1. The results for the leak test are provided in the table below:
Fuel Storage Container Date of Test Leakage (cc/sec)
A-35 June 21, 2010 7.33E-04
8-41 June 21, 2010 9.85E-04
C-41 June 21, 2010 5.10E-04
D-41 June 22, 2010 4.29E-04
E-41 June 22, 2010 7.65E-04
F-28 June 22, 2010 4.80E-04
SSW-1 June 22, 2010 4.89E-04
SSW-2 June 22, 2010 5.94E-04
SSW-3 June 22, 2010 4.14E-04
Technical Specification 3.1.1.1 required that the cooling inlet and outlet screens be
visually inspected every 7 days to verify that no blockage existed. If blockage was
observed on the screens, compensatory actions were required with specified time limits.
Through discussion with security personnel, it was identified that, on top of the weekly
checks, the security personnel checked both inlet and outlet vents daily during their
required rounds of the site. Records were reviewed for August 2007, December 2008,
June 2008, February 2009, November 2010, and December 2010. Procedure TPR-
5593, "Visual Inspection of Fort St. Vrain ISFSI Cooling Inlets and Outlets/Tornado
Clamp Verification," Revision 13, had been utilized to perform the visual inspections.
The licensee had completed the visual inspections in a timely manner and had identified
no obstructions during the months selected for review. The NRC inspector accompanied
the licensee during the weekly inspection conducted on March 9, 2011. No obstructions
were observed on the inlet and outlet screens during the inspection.
Safety Analysis Report Table 9.2.1 required the licensee to check the seismic restraints
on the crane weekly. Records for the months of August 2007, December 2008, June
2008, February 2009, November 2010, and December 2010 were reviewed. Procedure
TPR-5593, "Visual Inspection of Fort St. Vrain ISFSI Cooling Inlets and Outlets/Tornado
Clamp Verification," Revision 13, had been utilized to perform the visual inspections.
The licensee had completed the required visual check on the crane's seismic restraints
- 10 - ENCLOSURE
as required by the SAR with no discrepancies noted. The NRC inspector accompanied
the licensee during the weekly inspection conducted on March 9, 2011. The crane's
seismic restraints were verified as engaged.
g. Organization and Training
Requirements related to the ISFSI staffing were included in Section 9.1 of the SAR.
Figure 9.1-1 provided an organizational tree of command. The licensee provided
individual names for each of the positions listed in Figure 9.1-1. Employee qualification
reports, dated March 9, 2011, were reviewed to verify that the assigned individuals
currently met the training requirements listed in SAR Section 9.1.4.1. The individuals
assigned to the following positions were verified as having current training: ISFSI
Quality Assurance Manager, Fort St. Vrain Facility Director, Manager of ISFSI
Management, Fort St. Vrain ISFSI Manager, and Fort St. Vrain Facility Safety Officer.
Safety Analysis Report Section 9,1.3.1.1 required an ISFSI safety review committee for
Fort St. Vrain. The purpose of this committee was to evaluate the performance of the
staff level safety committees, review performance indicators, review 72.48 evaluations,
review evaluations for the oil and gas program, review changes to the Technical
Specifications, emergency procedure, and physical protection plan, approve license
amendment requests, and review preparations for major changes in operations. The
membership of the safety review committee was updated in writing when changes were
made. The most recent safety review committee membership change was dated
March 7, 2011. Section 9.1.4.1 of the SAR listed the training requirements for
committee members and alternates. Employee qualification reports, dated March 9,
2011, were reviewed to verify that all individuals had completed the required training
listed in Section 9.1.4.1. All training had been completed, except for one recently
appointed alternate (Critical Safety Alternate).
The Safety Review Committee's charter was reviewed against Technical Specification
5.2.1.4 and SAR Chapter 9.1.3.1.1 related to the committee's functions and purpose.
Technical Specification 5.2.1.4 required the safety review committee to meet at least
once every 12 months with at least three committee members present for a quorum.
The meeting minutes for the last three safety review committee meetings, dated
August 13, 2008, August 4, 2009, and July 14, 2010, were reviewed. All meetings had
at least three members, creating the required quorum. The issues discussed in the
meetings were consistent with the objectives specified in the committee's charter, the
SAR, and the Technical Specifications.
h. Quality Assurance and Audits
Both the Fort St. Vrain and Three Mile Island (TMI) - 2 ISFSI facilities used the same
DOE quality assurance program implementation requirements. The quality assurance
program for the Fort St. Vrain ISFSI was described in Chapter 11 of the SAR.
Implementation of the quality assurance requirements was accomplished using the
"Quality Assurance Requirements and Description (QARD)," DOE/RW-0333P,
Revision 10. No changes had been made to the QARD since the last inspection
performed in February 2006. The QARD was also used for the Yucca Mountain project
and had been revised numerous times since Revision 10. However, Fort St. Vrain had
not adopted the later revisions and remained at Revision 10.
- 11 - ENCLOSURE
The licensee had conducted two annual audits each year, under the QARD, since the
last inspection performed in February 2006. Each audit evaluated the effectiveness and
adequacy of implementation of the ISFSI procedures and processes for both ISFSIs
(Fort St. Vrain, TMI-2). Audits 06-ISFSI-AU-002 and 09-ISFSI-AU-002, dated
September 2006 and September 2009, respectively, were selected for review. In both of
the audits, the elements of the quality assurance program implemented at the Fort St.
Vrain ISFSI were rated as effective. All identified deficiencies were entered into the
licensee's corrective action system.
The licensee also performs approximately 10 surveillances each year since the last
inspection performed in February 2006. The surveillances evaluated various
requirements in areas including ISFSI maintenance, physical protection, emergency
preparedness, records management, administrative controls, and the safety review
committee. Deficiencies identified during the surveillances were entered into the
licensee's corrective action system. No significant deficiencies were identified.
Deficiency Reports
The licensee provided a list of the deficiency reports initiated in the corrective action
system since the last inspection. The licensee had initiated 94 deficiency reports
between the two ISFSIs (Fort St. Vrain, TMI-2). Six deficiency reports were selected for
additional review that related to ISFSI issues. All deficiency reports reviewed were
determined to be adequately resolved. No adversely developing trends were identified
in the deficiency reports reviewed.
j. Aging Management Program and License Renewal
NRC License SNM-2504 was issued to Public Service of Colorado in November 1991 for
the storage of spent fuel elements from the Fort St Vrain High Temperature Gas Cooled
Reactor (HTGCR). The Fort St Vrain HTGCR was shut down August 1989 and has
since completed decommissioning and license termination. Transfer of the spent fuel
elements from the shut down reactor facility to the Fort St Vrain ISFSI began
December 26, 1991, and was completed June 10, 1992. The ISFSI license issued in
1991 was for 20 years. On June 4, 1999 the license for the Fort St. Vrain ISFSI was
transferred to the DOE, who currently is the licensee for the facility. The DOE Idaho
Operations Office (DOE-ID) was assigned responsibility for the activities authorized by
Materials License SNM-2504. On November 10, 2009, DOE submitted an application
(Federal Register Notice 75FR30074) to the NRC for the renewal of the ISFSI license for
d of a.- additional 20 y The
lic J by
the
a period of an additional cu years. i nc application vvB5 currently under review u'y' the
NRC.
As part of the license renewal, DOE had proposed an aging management program. This
was prudent with the recent uncertainty of the Yucca Mountain project and the re-
evaluation by DOE concerning the options for the long-term storage and disposition of
the nations spent fuel inventory. Section 2, "Scoping Evaluation," of DOE's license
renewal application described the scoping process to determine if a structure, system, or
component (SSC) should be evaluated for inclusion in the aging management program
planned for implementation during the renewal licensing period. The criteria for inclusion
related to items important to safety and items not important to safety but whose failure
could prevent an important to safety requirement from being fulfilled. Specific criteria
was developed and used for the evaluation which identified 10 SSCs that should be
- 12 ENCLOSURE
evaluated. These included, for example, the fuel storage containers, structural concrete
on the modular dry vault storage building, structural steel on the charge face, the
container handling machine, and fuel in storage.
Section 3, "Aging Management Reviews," then performed an assessment of the SSC
and its subcomponents to evaluate the effects of aging on the SSCs ability to perform its
function during the renewal licensing period. The assessment involved four major steps:
(1) identification of in-scope subcomponents requiring aging management review
screening, (2) identification of materials and environments, (3) identification of aging
effects requiring management, and (4) determination of the activities/programs required
to manage the effects of aging. The aging analysis included the materials of
construction and the environment which the SSC was exposed to in the ISFSI and
addressed both the aging effects and the aging mechanisms. Potential aging
mechanisms were considered from industry experience and from various industry
standards groups such as the American Concrete Institute (ACI), American Society for
Metals (ASM), and American National Standards Institute (ANSI). The results of the
analysis determined that the only SSC that required management of aging effects during
the 20-year period of the license renewal extension was the MVDS concrete. This would
consist primarily of adding periodic visual inspections by personnel qualified and trained
in accordance with ACI 349.3R-02, "Evaluation of Existing Nuclear Safety-Related
Concrete Structures." Examinations had been performed in 2006 and 2009.
The fuel storage containers, which contain the spent fuel elements, were determined to
not need additional aging management. The metallic seals on the canisters were
already required to undergo 5-year testing in accordance with Technical
Specification 3.3.1. In February 2008 a video inspection of two of the vaults found the
exterior of the fuel storage containers to be in good condition. This was documented in
Engineering Design File 8612, "Fort St. Vrain ISFSI MVDS Fuel Storage Container and
Support Stool Aging Management Review," dated March 15, 2010.
DOE had added the aging management program to the SAR, Revision 8, as a new
Chapter 9.8. Based on comments from the NRC during the review of the aging
management program, DOE issued Revision 9 of the SAR to add visual inspections of
the inaccessible areas of the vault on a 10-year basis. The aging management program
was scheduled to start June 2014. Markers had already been placed on several
suspected cracks on the ISFSI exterior walls and were being monitored. No increase in
cracking had been measured.
1.3 Conclusions
The ISFSI facility was being maintained in good physical condition with no observable
deterioration. Radiological areas inside the facility were properly posted.
The emergency planning program was being maintained current. Drills, exercises, and
training were performed in accordance with requirements in the emergency plan.
Training and participation in drills/exercises were offered to offsite support agencies.
Changes to the emergency plan since the last NRC inspection were reviewed to verify
that the effectiveness of the plan was not reduced.
- 13 - ENCLOSURE
Radiological conditions at the facility had not changed since the last inspection.
Radiological surveys and contamination surveys were conducted in accordance with the
licensee's procedures. No abnormal conditions were identified.
The site environmental radiation protection program was being implemented to verify
radiation conditions at the ISFSI were in compliance with NRC radiation standards.
Environmental dosimeters were adequately located around the ISFSI to demonstrate
compliance with exposure limits to the public.
Biennial reports were sent to the NRC in accordance with 72.48(d)(2). Revisions to the
SAR and Technical Specifications since February 2006 were acceptable and within the
requirements of the 72.48 process.
Operational activities associated with inspection of cooling inlet and outlet screens,
performance of fuel storage container leak tests on a 5-year frequency, and checks of
the crane's seismic restraints had been conducted in accordance with the requirements
of the Technical Specifications.
The ISFSI organization was in compliance with SAR requirements for staffing and
qualifications of personnel. Training was being performed and documented for site
personnel to meet the requirements of the SAR. The SRC had met on an annual bases
and reviewed issues consistent with requirements in the SAR and Technical
Specifications.
The Quality Assurance organization had performed two audits annually with
approximately 10 surveillances annually since the last inspection of February 2006. The
ISFSI program elements reviewed had been described as effective. Identified
deficiencies had been entered into the licensee's corrective action system.
The corrective action system was being used to capture issues and document corrective
actions. All deficiency reports (DR) reviewed had been adequately resolved. No
adverse trends were identified.
An aging management program was developed as part of the 20-year license extension
application. The licensee evaluated the importance to safety aspects of the ISFSI and
systematically reviewed the potential areas in which periodic surveillances should be
performed to identify age related degradation issues over the next licensed period of the
facility. The primary area identified for additional observation was the condition of the
concrete structures.
2 Review of 10 CFR 72.48 Evaluations (60857)
2.1 Inspection Scope
Changes to the facility and procedures since the last inspection in February 2006 were
reviewed to determine if the licensee had performed the required evaluations in
accordance with 10 CFR 72.48.
- 14 - ENCLOSURE
2.2 Observations and Findings
Safety screenings and safety evaluations were performed in accordance with Procedure
MCP-2925, "Screen and Evaluate Changes." Several safety screenings were performed
since February 2006, but only two of the screenings required the additional level of
analysis required by a safety evaluation. Selected safety screenings and the two 72.48
safety evaluations documented as FSV-09-003 and FSV-09-004 were reviewed. The
72.48 evaluations removed the individual fuel element grapple, the transfer cask, and
the neutron source storage wells from the SAR and Technical Specifications. Since the
ISFSI was not licensed to handle individual fuel elements and the fuel was contained in
fuel storage containers which would be lifted by the container handling machine fuel
storage container grapple, the individual fuel element grapple was not needed. The fuel
storage container grapple was currently included on the list of items important to safety.
The transfer casks had been included in the original license and were used to transfer
the fuel elements from the Fort St. Vrain reactor facility to the ISFSI, but have since been
replaced by the TN-FSV casks that have current 10 CFR Part 71 licensees. The neutron
storage wells were originally designed to hold the six neutron source fuel elements
containing the Californium-252 neutron sources. However, the Cf-252 was removed
from the fuel elements prior to placement of the fuel elements in the ISFSI. The neutron
source storage wells were identical in design to the standby storage wells and, as such,
have been re-designated by the licensee as standby storage wells. No findings of
significance were identified for the screenings or evaluations reviewed.
Training and qualification records for personnel approved to perform 72.48 screenings
and evaluations were reviewed. All personnel had current qualifications documented in
the employee qualification report, dated March 9, 2011.
2.3 Conclusions
All safety screenings and evaluations had been performed in accordance with facility
procedures and 10 CFR 72.48 requirements by qualified personnel.
3 Exit Meeting
The inspectors reviewed the scope and findings of the inspection during an exit meeting
conducted at the conclusion of the onsite inspection on March 9, 2011. The licensee did
not identify any information as proprietary that was provided to, or reviewed, by the
inspectors.
- 15 - ENCLOSURE
SUPPLEMENTAL INSPECTION INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
T. Borst, Fort St. Vrain ISFSI Manager
K. Whitham, DOE-ID Facility Director
J. Newkirk, Fort St. Vrain Facility Safety Officer
R. Elwood, Manager of ISFSI Management
J. Leger, Security Coordinator, NSA
INSPECTION PROCEDURES USED
IP 60857 Review of 10 CFR 72.48 Evaluations
IP 60858 Away From Reactor ISFSI Inspection Guidance
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Discussed
None
Closed
None
ATTACHMENT
LIST OF ACRONYMS
ACI American Concrete Institute
ANSI American National Standards Institute
ASM American Society for Metals
cc/sec Standard cubic centimeters per second
CFR Code of Federal Regulations
CWI CH2M-WG Idaho, LLC
DOE Department of Energy
DR Deficiency Report
FSV Fort Saint Vrain
HTGCR High Temperature Gas Cooled Reactor
INL Idaho National Laboratory
ISFSI Independent Spent Fuel Storage Installation
MOU Memorandum of Understanding
mCi milliCurie
mR/hr milliRoentgen per hour
MVDS modular vault dry storage
NRC Nuclear Regulatory Commission
QARD Quality Assurance Requirements Document
RWP radiation work procedure
SAR Safety Analysis Report
SSC structures, systems, or component
SSW standby storage wells
TLD thermoluminescent dosimeter
TMI Three Mile Island
pR/hr microRoentgens per hour
• - 2 - ATTACHMENT
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