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UNITED STATES
NUCLEAR REGULATORY COMMISS1t@1NP ^(
° REGION IV t;.�..,.
5 611 RYAN PLAZA DRIVE, SUITE 400
40 * 4. ARLINGTON, TEXAS 76011-8064 „ E n
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April 4, 2001
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Ms Beverly A. Cook, Manager
Idaho Operations Office
U. S. Department of Energy
850 Energy Drive
Idaho Falls, ID 83401-1563
SUBJECT: NRC INSPECTION REPORT 72-09/01-01
Dear Ms. Cook:
On February 26-28, 2001, an NRC inspection was conducted at your Fort St. Vrain
Independent Spent Fuel Storage Installation (ISFSI). On March 8, 2001, a telephonic exit was
conducted concerning the results of the leak tests performed during the week of March 5, 2001.
As a result of this phone call, it was determined that the six fuel storage containers had passed
the 5-year leak test required by Technical Specification 3.3.1.
In addition to the activities related to the 5-year leak test, the inspection included a review of
selected technical specifications and design changes for the Fort St. Vrain facility. The
enclosed report presents the scope and results of that inspection. No violations of NRC
regulations were identified.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records component of NRC's document system (ADAMS).
ADAMS is accessible from the NRC Web site at http://www.nrc.ciov/NRC/ADAMS/index.html
(the Public Electronic Reading Room).
Should you have any questions concerning this inspection, we will be pleased to discuss them
with you.
Sincerely, umm.:
Dwig rit D. Chamberlain, Director
Division of Nuclear Materials Safety
Docket No.: 72-09
License No.: SNM-2504
Enclosure:
NRC Inspection Report
072-09/01-01
L''/7s64/ a 1e'7d'Zs
V-76- 0110n/ 2001-0880
U. S. Department of Energy -2-
cc w/enclosure:
Mr. Mark D. Gardner
TMI/FSV Facility Director
Department of Energy
Idaho Operations Office
850 Energy Drive
Idaho Falls, ID 83401-1563
Mr. Jan Hagers
TMI/FSV Licensing Project Manager
Department of Energy
Idaho Operations Office
850 Energy Drive
Idaho Falls, ID 83401-1563
Ms. Mary J. Fisher
General Manager, Nuclear
Public Service Company of Colorado
P. O. Box 840
Denver, CO 80201-0840
Mr. M. H. Holmes
Project Assurance Manager
Public Service Company of Colorado
16805 Weld County Road 19-1/2
Platteville, CO 80651
I Olairman
L/ Board of County Commissioners
of Weld County, Colorado
Greeley, CO 80631
Regional Representative
Radiation Programs
Environmental Protection Agency
Region 8
1 Denver Place
999 18th Street, Suite 1300
Denver, CO 80202-2413
Director
Laboratory and Radiation Services Division
Colorado Department of Public Health
and Environment
8100 Lowry Boulevard
Denver, CO 80230-6928
ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.: 72-09
License No.: SNM-2504
Report No.: 72-09/01-01
Licensee: U. S. Department of Energy
Facility: Fort St. Vrain Independent Spent Fuel Storage Installation (ISFSI)
Location: 16805 Weld County Road 19-1/2
Platteville, Colorado 80651
Dates: February 26-28, 2001
Inspector: J. Vincent Everett, Sr., Health Physicist
Approved by: D. Blair Spitzberg, Ph.D., Chief
Fuel Cycle and Decommissioning Branch
Division of Nuclear Material Safety
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EXECUTIVE SUMMARY
Fort St. Vrain ISFSI
NRC Inspection Report 72-09/01-01
The annual inspection of the Fort St. Vrain Independent Spent Fuel Storage Installation (ISFSI)
was completed to verify compliance with selected technical specifications and the facility
license. The facility was being maintained by Bechtel BWXT Idaho, LLC as the management
and operations contractor for the Department of Energy's (DOE) Idaho Operations Office.
DOE's Idaho Operations Office is the licensee. The spent fuel was being stored safely and the
facility had been properly maintained. The required 5-year leak test of selected fuel storage
canisters was completed. All six fuel storage canisters sampled passed the leak test.
Operation of an ISFSI (60855)
• The licensee was conducting operations at the Fort St. Vrain ISFSI in compliance with
their license and technical specifications. The facility was being maintained in good
physical condition (Section 1).
• The licensee completed their 5-year leak test of selected fuel storage containers.
Based on the results of the leak tests, the fuel storage container seals were determined
to be in compliance with Technical specification 3.3.1 (Section 1).
• The licensee had conducted several quality assurance audits. The audits reviewed a
wide range of issues and resulted in several findings that had been entered into the
licensee's corrective action program (Section 1).
Design Control of ISFSI Components (60851)
• All changes made to procedures since June 2001, had been reviewed by the licensee
and determined to not require a 10 CFR 72.48 safety evaluation. No changes had been
made to the facility structures. No issues were identified with the licensee's safety
review program (Section 2).
• The licensee was updating their safety review program to meet the new NRC
requirements which become effective April 5, 2001 (Section 2).
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Report Details
Summary of Facility Status
The Fort St. Vrain Independent Spent Fuel Storage Installation (ISFSI) is a modular vault dry
storage design developed by the 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 fuel at the Fort St. Vrain ISFSI.
The DOE Idaho Operations Office is the licensee for the Fort St. Vrain facility. Bechtel BWXT
Idaho, LCC (BBWI) was the assigned management and operations (M&O) contractor
responsible for day-to-day activities at the facility. During this inspection, the licensee
conducted the 5-year leak test of six of the fuel storage containers. Problems with a leak test
equipment valve resulted in the tests being repeated. A total of six fuel storage containers were
tested (one per storage vault). All six fuel storage containers passed the leak test.
1 Operation of an ISFSI (60855)
1.1 Inspection Scope
The annual inspection of the Fort St. Vrain facility was completed to verify compliance
with the facility license and selected technical specifications. A tour of the facility was
conducted to observe the condition of the building. During this inspection, the 5-year
leak test of selected fuel storage containers was conducted.
1.2 Observations and Findings
Technical Specification 3.1.1, "Cooling Inlet and Outlet," required the licensee to
perform a weekly visual inspection of the cooling inlet and outlet screens on the
Fort St. Vrain facility. The licensee performed a visual inspection daily as part of the
security rounds. On several occasions during the winter, frost was observed on the
cooling screens that exceeded 50 percent blockage. Technical Specification 3.1.1,
required the licensee to remove the blockage within 7 days. The licensee typically
removed the blockage soon after discovery. A tour of the facility included observation of
the condition of the screens. All screens were in good condition with no blockage. The
areas around the screens were clear of debris.
Technical Specification 5.0, "Administrative Controls," established responsibilities and
requirements for oversight of the Fort St. Vrain facility. These responsibilities were
reviewed with the facility director to determine if any changes to the DOE organization or
responsibilities assigned the facility director had been made since the last inspection.
No changes affecting the requirements in Section 5.0 of the technical specifications had
been made.
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Technical Specification 3.3.1, "Seal Leak Rate," requires the licensee to conduct a leak
test of the seals for the fuel storage containers every 5 years. The last leak test was
conducted in March 1996. The 1996 test was the first time the leak test had been
conducted. No leaking seals were detected. The leak test was performed on one fuel
storage container in each of the six vaults. If any of the six fuel storage containers were
found to be leaking greater than 1 X 10-3 standard cubic centimeters/second (cc/sec),
additional fuel storage containers were required to be tested. The leaking seals must be
replaced or the fuel storage canister transferred to a special storage well.
The Safety Evaluation Report for the Fort St. Vrain facility, Section 10.2, provided an
analysis of the radiological effect of the leak rate limit of 1 X 10-3 cc/sec. Based on all
247 fuel storage containers leaking at this rate, the offsite dose would be 0.1 mrem/yr.
This was well below the limit in 10 CFR 72.104 of 25 mrem/year dose to a member of
the public.
The licensee conducted the leak tests of the fuel storage containers using procedure
TPR-5594 "FSV ISFSI Leak Test Device Functional Test," Revision 8, and TPR-5604
"FSV ISFSI Fuel Storage Container O-Ring Vacuum Leak Test," Revision 11. The test
measured the ability of the double O-rings used on the fuel storage containers to
maintain a seal between the bolted lid and the body of the fuel storage container. These
metal O-rings were the type used for pressure vessel applications under harsh operating
conditions.
The leak test required that a vacuum be maintained between the two O-rings for a
period of 10 minutes with a leak rate of less than 1 X 103 cc/sec. The leak test was
conducted on one fuel storage container in each of the six vaults. The same fuel
storage containers were tested every 5 years to allow for trending of any leakage to
determine if the seal was deteriorating to the point that leakage could exceed the leak
rate limit before the next 5-year test.
The leak test was performed by three certified fuel handlers, two radiological control
technicians and a certified leak test examiner. Also in attendance was the DOE
Fort St. Vrain Facility Director and the Fort St. Vrain ISFSI Manager.
Section 9.3.5 of the Fort St. Vrain Safety Analysis Report and 10 CFR 72.192 require
the licensee to establish a certified fuel handler program. The licensee's program was
documented in procedure MCP-3043 "NRC Operations Department Training,"
Revision 4. This procedure and UFC-2353 "Fort St. Vrain ISFSI Training Program,"
Revision 0, were reviewed. A detailed list of specific training courses and job task
analysis requirements was included in the appendix to UFC-2353. The licensee's
certification process required a significant amount of training and demonstration of skills.
Prior to conducting the leak test, the training records for the certified fuel handlers were
reviewed. Two of the three certified fuel handlers meet all requirements. The third
certified fuel handler had completed the required class room training. During the period
prior to starting the leak tests, the required on-the-job training, under the oversight of a
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certified fuel handler, was completed and the third person was certified. Records were
maintained for each individual to verify completion of the required training.
During the period January 29 thru February 22, 2001, the licensee performed a
surveillance of the training records to verify that the certified fuel handlers had
completed all required training prior to starting the leak tests. Only minor issues were
identified during the surveillance.
The certified leak test examiner was required to meet the qualification criteria of the
American Society of Non-Destructive Testing Recommended Practices No. SNT-TC-1A,
Levels 1, 2 or 3. The person assigned as the certified leak test examiner was certified
as Level 1 and had completed training on the test equipment to be used for the leak
tests at Fort St. Vrain. Certification was valid until October 18, 2003. The requirement
for the certified leak test examiner to meet the requirements of SNT-TC-1A were
included in Appendix C to procedure TPR-5594 "FSV ISFSI Leak Test Device
Functional Test," Revision 8, and Appendix C to procedure TPR-5604 "FSV ISFSI Fuel
Storage Container O-Ring Vacuum Leak Test," Revision 11. This requirement was also
found in the original vendor procedures for the leak test equipment in
Specification 362F0351 "Specifications for Pressure and Vacuum Test Equipment for
Fuel Storage Containers and Storage Well Tubes," Revision C.
Test Procedure TPR-5594 "Fort St. Vrain ISFSI Leak Test Device Functional Test,"
Revision 8, was used by the licensee to functionally test the leak test device prior to
conducting the leak test on the fuel storage container seals. Functionally testing the
leak test device within 31 days of conducting the leak tests on the fuel storage container
seals was required by procedure TPR-5594. The licensee had conducted the required
functional test on the leak test device on February 26, 2001. In addition, the licensee
had calibrated the vacuum gauge, pressure readout and pressure sensor prior to the
functional test.
Test Procedure TPR-5604 was the primary procedure used for the leak test of the fuel
storage containers. This procedure was derived from the original vendor
Procedure 362F0356 "Fort St. Vrain Method for Leak Vacuum Testing the Fuel Storage
Containers and Storage Well Tubes," Revision C, dated July 11, 1991. The vendor
procedure had been developed by GEC Alsthom Engineering Systems, LTD who had
manufactured the test equipment. Procedure TPR-5604 was compared to
Procedure 362F0356 and found to be equivalent except for one area. This difference
was found in the table in Section 4 of Procedure 362F0356, concerning the acceptance
criteria. Section 4 provided a value of 0.82 inches water as the equivalent to the
1 X 10-3 cc/sec leak rate. The leak rate of 1 X 10-3 cc/sec as the acceptable leak rate
was established in Technical Specification 3.3.1. The licensee had incorporated a leak
rate of 0.5 inches water into procedure TPR-56O4, Step 4.1.33, as the acceptance
criteria. The licensee provided a copy of memo DPT-95-0319 dated June 27, 1995,
which explained the new acceptance criteria based on the specific probe being used for
the leak test and 20 feet of hose. This memo calculated a value of 0.537 inches water
as the equivalent to the leak rate criteria of 1 X 10-3 cc/sec. The hose on the leak test
equipment was measured and confirmed to be 20 feet in length. The 0.5 inches water
was determined to be an acceptable value.
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Prior to each leak test, the team leader conducted a briefing with the team members.
The briefing covered the activities to be performed, a discussion of special precautions
that should be taken if problems occurred and critical points during the procedure that
required special attention by the team members. The pre-job meetings were thorough
and effective.
The licensee had issued a radiation work permit for the leak test effort. Surveys were
conducted prior to the leak test and radiological controls were established to prevent
contamination spread during the leak tests. The dose rates in the work area averaged
0.2 mR/hr. No neutron levels were measured.
During the week of February 26, 2001, the licensee initiated the leak tests for the
Fort St. Vrain ISFSI. Several problems were encountered during the tests. Dirt had
accumulated on the lid to the fuel storage containers. The lids were not accessible
without removing the large shield plugs. Only the test port on the lid was accessible.
When the bolt was removed from the test port on the lid using a 3-foot long tool
extended down a special hole in the shield plug, dirt would fall into the test port hole.
This created problems obtaining an adequate seal on the test probe when it was
screwed into the test port hole. A vacuum system, using a tube and a high efficiency
particulate filter (HEPA), was assembled to remove the dirt from around the test port.
This resolved the sealing problem and the tests continued.
During the testing of the fifth fuel storage canister, the licensee observed a drop in one
of the system pressure gauges without any change in the gauge used for determining
whether the test passed. Evaluation of the problem found that failure to close a bypass
valve completely on the test device allowed leakage of the vacuum from the system
without registering a reading on the pressure differential gauge used to measure the
vacuum drop on the seals. The licensee evaluated this problem and made changes to
the procedure to ensure the valve was closed completely. Because the licensee had not
verified the reading on the system pressure gauge at the end of each test to ensure no
leakage within the test system had occurred, then all test results were invalidated. The
licensee conducted an in-depth evaluation of the test equipment to ensure no other
possible failure modes existed. The leak tests were re-run the week of March 5, 2001.
On March 8, 2001, the licensee completed the tests of all six fuel storage containers and
confirmed that no containers leaked above the limit of 0.5 cc/sec. The following table
presents the final results of the leak tests.
FUEL STORAGE DATE OF GROSS NET
CONTAINER # TEST LEAK RATE LEAK RATE
A35 3/8/01 0.0192 cc/sec 0
B41 3/8/01 0.084 cc/sec 0.0558 cc/sec
C41 3/8/01 -0.0132 cc/sec 0
D41 3/7/01 0.0192 cc/sec 0
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FUEL STORAGE DATE OF GROSS NET
CONTAINER # TEST LEAK RATE LEAK RATE
E41 3/8/01 0.117 cc/sec 0.0888 cc/sec
F28 3/8/01 0.051 cc/sec 0.0228 cc/sec
Of the six fuel storage containers, three showed no leakage. The three that showed
some level of leakage were all less than 0.1 cc/sec. The net leak rate was determined
by subtracting the leak rate measured for the test equipment at the beginning of the test
from the gross leak rate measured for each fuel storage canister. Prior to the start of
. the leak tests for the six fuel storage canisters, the functional test of the leak test
equipment measured a leak rate of 0.0282 cc/sec. This value was subtracted from the
gross leak rate to determine the net leak rate. At the conclusion of the six leak tests,
the leak test equipment was again functionally tested. A leak rate of 0.066 cc/sec was
measured.
No radiation was detected on the end of the test probe at the completion of each leak
test and no radiation readings were observed on the vacuum hose during the tests. No
contamination problems were encountered during the tests and good radiological
controls were exhibited by the radiation protection staff.
Based on the results of the leak tests, the fuel storage container seals were determined
to be in compliance with Technical specification 3.3.1.
During this inspection, the licensee's quality assurance oversight of the Fort St. Vrain
facility was reviewed. Several audits of the spent fuel storage program, including the
Fort St. Vrain facility and operations, had been conducted since June 2000. A quality
assurance audit was conducted August 14-24, 2000, by the DOE quality assurance
organization focusing on the implementation of the BBWI quality assurance program.
Audit findings included an evaluation of the work environment at the test area north
facility in Idaho related to recent apprehension expressed by workers concerning the
freedom to bring problems to management's attention, lack of a formal written program
for the quality engineering position, training of instrument technicians, inspector
evaluations and entry of records into the electronic data management system. All
issues had been entered into the licensee's corrective action process.
Technical Safety Audit 01-ISFSI-AU-003, conducted on November 13-22, 2000,
included an evaluation of the effectiveness of the maintenance program, health physics
program, facility change program and controlled material accountability program.
Several issues were identified related to control and retreivability of records, control of
inventory items with limited shelf life and accuracy of the inventory database. The
licensee had entered the issues into the corrective action program.
In addition to the DOE audits, BBWI had conducted an audit and issued an audit report
on December 15, 2000, concerning the review of quality assurance activities related to
the Fort St. Vrain ISFSI and the Three Mile Island (TMI-2) ISFSI located in Idaho.
-8-
Issues identified during the audit related primarily to the TMI-2 ISFSI and included
documentation of the heated vacuum drying cycle, monitoring of the dry storage cask
temperature during transfer and problems with training records being inputted into the
"TRAIN" record system.
1.3 Conclusions
The licensee was conducting operations at the Fort St. Vrain ISFSI in compliance with
their license and technical specifications. The facility was being maintained in good
physical condition.
The licensee completed their 5-year leak test of selected fuel storage containers.
Based on the results of the leak tests, the fuel storage container seals were determined
to be in compliance with Technical Specification 3.3.1.
The licensee had conducted several quality assurance audits. The audits reviewed a
wide range of issues and resulted in several findings that had been entered into the
licensee's corrective action program.
2 Design Control of ISFSI Components (60851)
2.1 Inspection Scope
A review of changes made at the Fort St. Vrain facility since the June 2000 NRC
inspection, were reviewed.
2.2 Observations and Findings
The licensee had made 32 changes to procedures since June 2000. These changes
had been screened in accordance with 10 CFR 72.48 and found to not require a safety
evaluation. The list of procedure changes was reviewed during this inspection. No
changes to the facility were performed during the period since June 2000. No issues
were identified related to the design change program during this inspection.
The licensee was revising the safety review program to comply with the new
requirements of 10 CFR 72.48 that will become effective April 5, 2001. Procedure
MCP-2925 "Screen and Evaluate Changes," was being revised. Re-training was
scheduled for all affected personnel.
2.3 Conclusions
All changes made to procedures since June 2001, had been reviewed by the licensee
and determined to not require a 10 CFR 72.48 safety evaluation. No changes had been
made to the facility structures. No issues were identified with the licensee's safety
review program.
-9-
The licensee was updating their safety review program to meet the new NRC
requirements which become effective April 5, 2001.
3 Follow-up of Open Items (92701)
3.1 (Discussed) IFI 72-09/97297-22 Quality Assurance Records: NRC Inspection
Report 72-09/97-207 identified that the licensee had not performed a receipt inspection
of the fabrication records for the two Transnuclear-Fort St. Vrain spent fuel shipping
casks received from Public Service of Colorado during the license transfer process. The
licensee subsequently performed a detailed review of the records and identified a
number of documents that were either missing, incomplete, or in the case of several
drawings, were not clearly legible. The licensee was continuing its effort to correct the
deficiencies. Recent efforts have involved Transnuclear West and Oak Ridge National
Laboratory. Oak Ridge National Laboratory was considering using the shipping casks
and was supporting the effort to resolve the open item.
4 Exit
The inspector presented the inspection results to members of licensee management at
the conclusion of the inspection on February 28, 2001. On March 8, 2001, a telephonic
exit was conducted with the licensee after completion of the 5-year leak test. As a result
of the March 8, 2001, phone call, it was determined that the six fuel storage containers
passed the required Technical Specification 3.3.1 leak test requirements. The licensee
acknowledged the findings presented. The licensee did not identify as proprietary any
information provided to, or reviewed by, the inspector.
ATTACHMENT
PARTIAL LIST OF PERSONS CONTACTED
DOE (Licensee)
B. Davis, Quality Assurance Manager
M. Gardner, DOE TMI-2/Fort St. Vrain Facility Director
Bechtel BWXT Idaho, LLC (M&O Contractor)
T. Borst, Fort St. Vrain ISFSI Manager
R. Butler, Radiological Control Technician
R. Elwood, Certified Fuel Handler
J. Kaylor, Operations Manager
D. Klinger, Leak Test Examiner, Level 1
S. Larsen, Certified Fuel Handler
J. Newkirk, Fort St. Vrain Facility Safety Officer
J. Spells, Certified Fuel Handler
Other Contractors
J. Leger, Fort St. Vrain Security Supervisor, Burns International Security Services
INSPECTION PROCEDURES USED
60851 Design Control of ISFSI Components
60855 Operation of an ISFSI
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Closed
None
Discussed
72-09/97207-22 IFI Quality Assurance Records
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LIST OF ACRONYMS
BBWI Bechtel BWXT Idaho, LLC
CFR Code of Federal Regulations
DOE-ID Department of Energy - Idaho Operations Office
FSV Fort St. Vrain
ISFSI Independent Spent Fuel Storage Installation
M&O Management and Operations Contractor
MVDS Modular Vault Dry Storage
NRC Nuclear Regulatory Commission
PSCo Public Service of Colorado
SAR Safety Analysis Report
SNM Special Nuclear Material
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