HomeMy WebLinkAbout992847.tiff ?J``flR HQC0 UNITED STATES
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REGION IV
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611 RYAN PLAZA DRIVE,SUITE 400 • n. O 6
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**e++ ARLINGTON,TEXAS 76011-8064
November 17, 1999
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 72-09/99-01
Dear Ms. Cook:
On September 27-30, 1999, an NRC team inspection was conducted at your Fort St. Vrain
Independent Spent Fuel Storage Installation (ISFSI). The enclosed report presents the scope
and results of that inspection. On November 16, 1999, a followup telephonic exit was held
between the NRC Inspection Team Leader and your staff. During this discussion, additional
information was provided by the NRC concerning the non-cited violation identified in this report.
The inspection included a review of activities associated with the environmental monitoring
program, safety evaluations completed for the facility, condition of the facility, compliance with
technical specifications, radiological conditions, personnel training, emergency planning and
quality assurance program implementation.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be placed in the NRC Public Document Room.
Should you have any questions concerning this inspection, we will be pleased to discuss them
with you.
Sincerely,
Dwig t D. Chamberlain, Director
Division of Nuclear Materials Safety
Docket Nos.: 72-09
License Nos.: SNM-2504
Enclosure:
NRC Inspection Report
72-09/99-01
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992847
U. S. Department of Energy -2-
cc w/enclosure:
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
Chairman
Board of County Commissioners
of Weld County, Colorado
Greeley, Colorado 80631
Regional Representative
Radiation Programs
Environmental Protection Agency
Region 8
1 Denver Place
999 18th Street, Suite 1300
Denver, Colorado 80202-2413
Robert M. Quillin, Director
Laboratory and Radiation Services Division
Colorado Department of Public Health
and Environment
8100 Lowry Boulevard
Denver, Colorado 80220-6928
ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.: 72-09
License No.: SNM-2504
Report No.: 72-09/99-01
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: September 27-30, 1999
Inspectors: J. Vincent Everett, Sr. Health Physicist
Fuel Cycle and Decommissioning Branch
Division of Nuclear Materials Safety
Rachel S. Carr, Health Physicist (Inspector-in-Training)
Fuel Cycle and Decommissioning Branch
Division of Nuclear Materials Safety
Dennis Reid, Safety Inspector
Office of Nuclear Materials Safety
and Safeguards, Spent Fuel Project Office
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 72-09/99-01
The Fort St. Vrain Independent Spent Fuel Storage Installation (ISFSI) has been in operation
since December 1991. The facility had been maintained and operated by Public Service
Company of Colorado until June 4, 1999, at which time the NRC license was transferred to the
U. S. Department of Energy (DOE). The Idaho Operations Office of the DOE was assigned
responsibility for the Fort St. Vrain facility. This inspection was the first annual inspection since
DOE assumed responsibility for the facility. The primary onsite staff at the ISFSI had
transferred from Public Service Company of Colorado to the management and operations
contractor for DOE and remained onsite at the Fort St. Vrain ISFSI. This provided for the
historical knowledge and operational experience of the facility to be carried over to DOE. The
annual inspection of the ISFSI found the transfer of the license to DOE to have been completed
with very few problems. Most of the problems had involved DOE's quality assurance program.
An extensive NRC evaluation of the quality assurance program was completed as part of the
DOE license request for the TMI-2 ISFSI, located at the Idaho National Engineering and
Environmental Laboratory. DOE's corrective actions for the problems related to the TMI-2
ISFSI quality assurance program were also implemented for the Fort St. Vrain program.
Overall, the NRC inspectors observed no reduction in the effectiveness of the programs being
implemented at the ISFSI and noted that the resources available within DOE strengthened the
overall capabilities for response to problems or emergency conditions at the facility.
Operation of an ISFSI - Annual Inspection
• The Fort St. Vrain ISFSI and equipment were being maintained in good physical
condition. Work on the new security center was nearing completion (Section la).
• Environmental dosimetry data for 1998 was reviewed. Radiation exposure rates around
the ISFSI were found to be near background levels. No releases of radioactive effluents
had occurred (Section 1b).
• Numerous quality assurance audits and surveillances were conducted in 1998 and
1999. The audits were comprehensive and covered a number of technical and
administrative areas. Issues identified were being tracked and adequately closed by the
licensee. Surveillances were being completed within required time frames identified in
the technical specifications. One Non-Cited Violation (NCV) was identified related to
qualifications of quality assurance engineers. (Section 1c and 1d).
• Radiological surveys were being performed as required. Survey instrumentation was
found to be calibrated. Survey results confirmed radiation levels consistent with
historical levels and supported the results of the environmental dosimetry data. The
neutron source was properly stored and posted (Section 1 e).
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• General employee training was current for personnel assigned to the Fort St. Vrain
ISFSI. Thirty individuals were qualified for unescorted access and had been trained.
Certified fuel handler training was being completed in accordance with the biennial
requirement of the safety analysis report (Section 1f).
• Changes to the site emergency plan were reviewed and found to be acceptable. A new
hospital had been identified as the primary care center. The hospital provided better
capabilities for medical care than the previously identified hospital (Section 1g).
• Safety reviews performed by the licensee for 1998 were reviewed. Safety screenings
and evaluations were found to be adequate. Safety evaluations performed were related
to new activities associated with natural gas wells and pipelines within 1/2 mile of the
ISFSI (Section 1h).
• Eight inspection followup items were reviewed during this inspection. Six were closed.
The two issues remaining open involved the quality assurance records associated with
the Transnuclear-Fort St. Vrain shipping cask and corrective actions associated with
issues under review by the safety review council (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 provides
storage for the spent fuel from the Fort St. Vrain high temperature gas cooled reactor, which
was decommissioned. There were 1458 spent fuel elements and 6 source elements in storage
at the Fort St. Vrain ISFSI.
The Fort St. Vrain ISFSI had been managed by Public Service of Colorado until June 1999.
The NRC approved the transfer of the Fort St. Vrain license to the U. S. Department of
Energy (DOE) on June 4, 1999. DOE's Idaho Operations Office was assigned responsibility for
the Fort St. Vrain facility. Lockheed Martin Idaho Technologies Company, as the assigned
management and operations contractor, was responsible for the day-to-day activities at the
ISFSI.
On June 9, 1999, DOE informed the NRC that a new management and operations contractor
had been selected for the Idaho National Engineering and Environmental Laboratory. The new
management and operations contractor would be Bechtel B&W Idaho replacing Lockheed
Martin Idaho Technologies Company effective October 1, 1999. Bechtel B&W Idaho would be
responsible for the activities associated with the Fort St. Vrain ISFSI. Notification of the NRC
concerning the new management and operations contractor complied with License Condition 14
of the DOE license for the Fort St. Vrain ISFSI. No significant changes to the staffing for the
Fort St. Vrain ISFSI was expected.
1 Operations of an ISFSI (60855)
1.1 Inspection Scope
This routine annual inspection of the Fort St. Vrain ISFSI included a review of the facility
condition and staffing, environmental monitoring program, quality assurance program,
selected technical specifications, radiological conditions, training, emergency planning
and safety evaluations completed for the facility.
1.2 Observation and Findings
a. Facility Condition and Staffing
A tour of the ISFSI was conducted. The facility was in good physical condition.
Housekeeping was excellent. Security seals on the fuel were in place. The new
security building was under construction. The security building was attached to the
ISFSI and will replace the current security facility that is located in the Fort St. Vrain
reactor facility. Testing of the security facility is planned to begin before the end of
1999.
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The morning staff meeting was attended by the NRC inspection team. A status of the
work activities related to the security building were reviewed. No significant construction
problems were occurring. Plans for testing and acceptance of the security facility and
systems were discussed during the meeting. Scheduled surveillances for the upcoming
week were assigned.
b. Environmental Monitoring Program
The Fort St. Vrain ISFSI annual environmental report for 1998, which covered the period
from January 1 through December 31, 1998, was reviewed. Environmental monitoring
at the Fort St. Vrain ISFSI was conducted by Colorado State University for the period
January 1 through June 30, 1998, and by URS Greiner Woodward Clyde for the period
July 1 through December 31, 1998. The new contractor's sample analysis capability
was equivalent to the previous contractor's. A vendor audit of the new contractor was
conducted by the licensee on June 29, 1998. The vendor was determined to be fully
qualified.
Environmental radiation monitoring around the ISFSI facility was performed using
20 thermoluminescent dosimeters (TLD). Six additional dosimeters were located inside
the ISFSI building. The average gamma exposure rate for the dosimeters located both
inside the ISFSI building and around the outside of the facility was 0.40 mR/day. This
was consistent with the exposure rates measured over the last several years. Review of
the environmental data provided in the 1998 environmental report indicated there were
no releases of radioactive effluents from the ISFSI and direct radiation exposure rates
were negligible compared to background levels.
At the time of this inspection, the direct radiation monitoring locations were being
monitored by both the management and operations contractor for the Operations Office
and by URS Greiner Woodward Clyde. Future plans were to transition the
environmental monitoring program to the management and operations contractor.
The TLD processing time for 1998 and 1999 was reviewed. The period between the
annealing of the TLD prior to use and the time when the TLD is processed is called the
wear time. For the Fort St. Vrain TLDs, the wear time in 1998 had been 188 days. For
1999, wear time had increased to 240 days. Data fading issues can result from long
wear times. The data reviewed for 1998 found a slight discrepancy for the fourth
quarter 1998 data which could be due to fading. Though the discrepancy was not
significant and the TLD values recorded were within the error bands for the expected
environmental radiation levels, the poor practice and potential problems of allowing high
wear times for environmental TLDs was discussed with the licensee. The licensee
stated that this issue should be resolved when the TLD program responsibilities are
assumed by DOE Idaho's management and operations contractor.
c. Quality Assurance/Surveillances/Problem Reports/Non-Conformance Reports
On May 24-27, 1999, DOE's quality assurance organization conducted an evaluation of
the quality assurance program being implemented at the Fort St. Vrain site for the
construction of the security alarm station. Surveillance No. 99-NSNF-S-053 was issued
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June 7, 1999. The work underway at the time of this surveillance included the pouring
of the concrete foundation for the alarm station and excavation of the camera pad
location. Several concerns were identified related to acceptance criteria, codes and flow
down of requirements to suppliers. One corrective action request was identified related
to the lack of an organizational description for the alarm station project. This corrective
action request was closed on June 28, 1999, with the issuance of a letter delineating
responsibilities. On September 15, 1999, a followup memo was issued which related to
the other concerns identified in the quality assurance audit. Each concern that was
addressed related to actions completed and actions remaining. The licensee was
tracking completion of the issues.
On May 17, 1999, a quality assurance audit of Fort St. Vrain was conducted by DOE
focusing on the corrective action requests in DOE Audit Report 98-NSNF-AU-034,
published on November 19, 1998, and the inspection followup items identified in NRC
Inspection Report 72-009/98-201. The audit team determined that the corrective actions
for the NRC followup items had been satisfactorily implemented. The audit team found
that the corrective action requests identified in the DOE audit report were either
satisfactorily completed or were being processed in a way that should result in
satisfactory completion. Each of the corrective action request items were discussed in
the audit team report. The audit team completed a thorough evaluation of the issues.
An independent oversight assessment of the Fort St. Vrain ISFSI and the Three Mile
Island ISFSI was performed during a period of July 19 through August 19, 1999, by
Lockheed Martin Idaho Technologies Company. This assessment, issued as
Report No. 99-MDA-016, covered the NRC licensed activities at the two ISFSIs including
requirements specified in each facility's safety analysis report. Topics reviewed included
emergency planning, security, training, operations, radiation protections, and safety
reviews. A number of findings were issued as part of this assessment including
problems noted in the areas of training for 10 CFR Part 21 reportability, lack of specific
written procedures for the Fort St. Vrain natural gas and oil monitoring program, lack of
training for the safety review committee members on the Fort St. Vrain technical
specifications, and hand written corrections on quality assurance records that were not
initialed and dated. The assessment also found that personnel assigned as
Fort St. Vrain quality assurance engineers did not meet the requirements in the safety
analysis report, Section 9.1.3.1 "Minimum Qualification Requirements." The safety
analysis report required the Fort St. Vrain quality assurance engineers to be certified as
lead auditors. The assigned Fort St. Vrain quality assurance engineers were not
certified as lead auditors. This was in noncompliance with Technical Specification 5.3.1
of the Fort St. Vrain license which required each member of the facility staff to meet the
minimum qualifications specified in the safety analysis report. This Severity Level IV
violation is being treated as a Non-Cited Violation, consistent with Section VI1.B.1.h of
the Enforcement Policy (NCV 72-09/9901-01). The final assessment report was issued
on September 15, 1999. The licensee initiated process deficiency report No. 8910 on
October 6, 1999, to track resolution of the qualifications issue. On October 14, 1999,
DOE issued Licensee Event Report No. 99-02-00 to the NRC reporting this technical
specification noncompliance in accordance with the 30-day reporting requirement in
Technical Specification 5.6.2.
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On August 23, 1999, Public Service Company of Colorado notified the NRC in
accordance with 10 CFR72.11, of problems concerning purchases of bullet resistant
steel, hinges on a bullet resistant door and bullet resistant glass that had been
purchased for use in the new security alarm station at the ISFSI. Three problem reports
were issued by the licensee. Problem Report 99-08-008, issued August 20, 1999,
described the problem with the bullet resistant steel. A purchase order had been issued
to the vendor ordering Shot-Tex #4 bullet resistant wall armor. Shot-Tex #4 met the
requirements of American Society for Testing and Materials (ASTM) 514 Grade B for
bullet resistant properties. The steel plate received from the vendor had no physical
markings and no Certificate of Compliance confirming the qualifications of the steel. A
sample of the steel plate was sent to a laboratory for analysis. The analysis found the
steel plate to be mild steel. In the meantime, the vendor provided the licensee with a
certificate stating that the steel plate was ShotTex #4 bullet resistant wall armor. The
vendor was contacted about the discrepancy. The vendor determined that a mistake
had been made in filling the order and replaced the steel plate with the correct steel.
The problem report was closed on September 9, 1999.
Problem Report 99-08-009 described the problem with two bullet resistant window glass
assemblies. One window glass was chipped. The second window glass was found to
have a crack. New glass was ordered from a different vendor. The new glass had not
arrived on site, as of the date of this inspection.
Problem Report 99-08-010 discussed the hinges on the bullet resistant door. Stainless
steel hinges had been ordered. However, the hinges received on the bullet resistant
door were discovered to be carbon steel. The vendor subsequently provided stainless
steel replacement hinges. The problem report was closed on September 20, 1999. All
three problem reports related to the same vendor.
d. Technical Specification
Technical Specification 5.4.1 established requirements for written procedures, including
procedures for health physics, design control, facility changes, spent fuel management,
emergency response, quality assurance, radiological environmental monitoring, training,
procedure and program changes, natural gas and oil monitoring and radiological effluent
control. A review was conducted of the licensee's procedures and programs. Adequate
procedures had been developed and were being implemented for all the areas listed in
Technical Specification 5.4.1.
The natural gas and oil monitoring program was reviewed. This program maintained a
database of the locations for all the oil and gas wells and pipelines, within a 1 mile
radius of the Fort St. Vrain ISFSI. The program was being maintained current by the
licensee.
Surveillance and maintenance activities were reviewed for the period 1998 through
September 1999. Technical Specification 3.3.1 "Seal Leak Rate," required the licensee
to leak test one fuel storage container vault every 5 years. The next leak test was not
due until 2001 based on the last test being completed in 1996.
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Technical Specification 3.2 "Container Handling Machine" required the container
handling machine to be tested when the handling machine was in use or 31 days prior to
lifting. A visual inspection was required for the crane hoist dead stop device every
12 months. The 12-month required inspection was a new requirement added when the
license was transferred from Public Service of Colorado to DOE. Based on the license
transfer date of June 4, 1999, this inspection activity was not due.
The modular vault dry storage cooling system was required to be visually inspected on a
weekly basis per Technical Specification 3.1. The weekly surveillances were being
conducted in accordance with Procedure TPR-5593, Revision 5, "Visual inspection of
Fort St. Vrain ISFSI cooling inlets and outlets/tornado clamp verification." Surveillance
documentation was reviewed for the period June 9 through September 29, 1999. The
surveillance conducted on September 29, 1999, under work order Number 17747, was
observed by the NRC inspector. Fort St. Vrain received the work order package from
Idaho National Engineering and Environmental Laboratory, approximately 1- week prior
to the required surveillance date. The work order package contained the required
surveillance, supporting documentation, forms and dispositioning forms. A pre-job
briefing was conducted prior to initiating the surveillance. The briefing and surveillance
of the cooling inlets/outlets was conducted satisfactorily.
Procedure TPR-5593 required verification of the position of the tornado clamps on the
crane. This portion of the surveillance was performed by observing the orange and red
light illumination on the crane control pendant. The red lamp indicated the tornado
restraint bridge clamps were set for the crane on both the east and west rails. The red
light was out during the surveillance conducted on August 4, 1999. The light was
replaced and determined operational. The red light was observed as being out again on
September 7, 1999. A purchase order was in the process of being initiated in order to
resolve the lamp problem through the vendor. The licensee had discussed the situation
with the vendor, who suggested to turn the crane on. One clamp, however, would still
not release. This condition would prevent the crane from being operated because it
could not be released from the restraint. The crane was in a secure and safe position
with the clamp engaged. This was verified by the NRC inspector, who visually inspected
the hydraulic gauge which indicated pressure was applied to the clamp.
e. Radiological Conditions
Radiological surveys for the Fort St. Vrain ISFSI were performed in accordance with
Technical Procedure TPR-5613, Revision 4, "FSV ISFSI Radiation Survey and Vault
Drain System Sample Collection and Analysis." The procedure required radiological
surveys to be conducted on a quarterly basis. The last survey was completed on
July 15, 1999. Surveys conducted prior to the license transfer to DOE on June 4, 1999,
were in the records transmittal storage vault and were not reviewed. The survey data
indicated background levels and supported the data in the annual radiological
environmental report.
The licensee conducted weekly source checks of the radiation instrumentation. Weekly
source checks were required by Procedure MCP-93, Revision 1, "Health Physics
Instrumentation," Appendix A. When instruments were being used, source checks were
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required to be conducted on a daily basis. The NRC inspector observed the licensee
correctly performing source checks on an RM-14 beta-gamma detector, microRem
meter, RO-20 beta-gamma detector, and an ESP neutron detector, under RWP 99-03,
"Source Check Radiation Instruments." Calibrations were performed for the Fort St.
Vrain facility by DOE's Instrumentation Laboratory in Idaho Falls. An AM-Be source
consisting of 840 mCi Am-241 was stored onsite and used as a source check for the
neutron instrument. The source was stored in a locked fire-proof safe and posted as a
radiation area. Dose rates from the Am-Be source were 22 mrem/hr contact and 4.5
mrem/hr at 12 inches. The weekly surveys of the source locker were reviewed from the
period June 7 through September 7, 1999.
f. Training
Training records for general employee training and certified fuel handler training were
reviewed. There were 30 individuals currently qualified for unescorted access to the
ISFSI. The training records for an individual selected by the NRC inspector were
reviewed against the requirements in Procedure MCP-2965, "Training Procedure,"
Revision 1. The individual's general employee training record was current.
The training requirements for the certified fuel handlers were specified in MCP-2968,
"Training of Certified Fuel Handlers," Revision 5. The certified fuel handler training
program included general employee training, radworker II, equipment and component
design description, accident analysis, regulations and procedures, and operation of the
different handling devices, crane and container handling machine. Certified fuel handler
training was required biennially. The licensee was conducting training on an annual
basis in order to complete all required course work within the 2-year period. The ISFSI
Manager and the Facility Safety Officer training records were reviewed. Training for the
two individuals was found to be complete and in accordance with Procedure MCP-2968
requirements.
The ISFSI protected area authorization list was updated by the facility safety officer
each month and provided to the security supervisor. The authorization list was verified
when security logged an individual into the ISFSI protected area. The ISFSI manager
and the facility safety officer were the instructors who provided general employee
training. In the event an individual on the authorization list did not pass their general
employee training, the facility safety officer would delete the individual's name from the
authorization list for the protected area.
g. Emergency Planning
On January 11, 1999, the licensee sent a letter to the NRC describing two changes to
the site emergency plan and procedures. The first change involved the hospital that
would be used for emergency patient care. A new hospital, North Colorado Medical
Center, was identified as the primary care center for contaminated and injured persons.
This medical facility provided better capabilities than the previous medical center and
was approximately the same distance from the facility.
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The second change made to the emergency planning program involved the radiological
environmental monitoring program. A new vendor had been designated to provide this
service when the prior vendor decided to discontinue offering the service. Both changes
were determined to be acceptable and to not reduce the effectiveness of the licensee's
ability to respond to an emergency condition.
h. Safety Evaluation
A letter was sent to the NRC on December 17, 1998, providing the list of annual
changes to the safety analysis report. The Safety Analysis Report, Revision 10, was
updated in accordance with the annual update requirements specified in 10 CFR 72.70.
No modifications during 1998 were made to the Fort St. Vrain ISFSI. No changes to
codes, standards, regulations, or regulatory guides committed to by the licensee were
identified during 1998. Changes made to the safety analysis report included clarification
concerning the storage of the neutron source onsite, addition of information concerning
new natural gas wells and a 24-inch natural gas supply pipeline in the vicinity of the
ISFSI, addition of a 12°F low temperature operating limit for spent fuel handling
movement to prevent brittle fracture of the fuel storage containers, and the addition of
information concerning the atmospheric tritium monitoring program.
On December 15, 1998, the licensee submitted a letter to the NRC summarizing the
10 CFR 72.48 changes that had been completed during 1998. No changes had been
made to procedures described in the safety analysis report and no tests or experiments
were conducted. During this inspection, seven screening forms were reviewed by the
inspectors. Screening forms provided the basis for determining whether an issue
required a safety evaluation. The issues screened by the licensee involved new
procedures for the security alarm station and a change to a procedure to reference the
new technical specifications. The screening forms that were reviewed by the inspectors
correctly concluded that no safety evaluations were required.
Several safety evaluations had been performed by the licensee. These safety
evaluations were related to nearby activities associated with the natural gas facilities in
the local area. Technical Specification 5.5.3 "Natural Gas and Oil Monitoring Program,"
required the licensee to maintain a program to monitor activities associated with natural
gas and oil facilities within /z mile of the ISFSI. The safety evaluations determined that
issues associated with the natural gas facilities were bounded by previously evaluated
postulated accident consequences and were allowed based on the requirements
established in 10 CFR 72.48.
1.3 Conclusions
The Fort St. Vrain ISFSI and equipment were being maintained in good physical
condition. Work on the new security center was nearing completion.
Environmental dosimetry data for 1998 was reviewed. Radiation exposure rates around
the ISFSI were found to be near background levels. No releases of radioactive effluents
had occurred.
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Numerous quality assurance audits and surveillances were conducted in 1998 and
1999. The audits were comprehensive and covered a number of technical and
administrative areas. Issues identified were being tracked and adequately closed by the
licensee. Surveillances were being completed within required time frames identified in
the technical specifications. One Non-Cited Violation (NCV) was identified related to
qualifications of quality assurance engineers.
Radiological surveys were being performed as required. Survey instrumentation was
found to be calibrated. Survey results confirmed radiation levels consistent with
historical levels and supported the results of the environmental dosimetry data. The
neutron source was properly stored and posted.
General employee training was current for personnel assigned to the Fort St. Vrain
ISFSI. Thirty individuals were qualified for unescorted access and had been trained.
Certified fuel handler training was being completed in accordance with the biennial
requirement of the safety analysis report.
Changes to the site emergency plan were reviewed and found to be acceptable. A new
hospital had been identified as the primary care center. The hospital provided better
capabilities for medical care than the previously identified hospital.
Safety reviews performed by the licensee for 1998 were reviewed. Safety screenings
and evaluations were found to be adequate. Safety evaluations performed were related
to new activities associated with natural gas wells and pipelines within ''Y2 mile of the
ISFSI.
2 Follow-up of Open Items (92701)
2.1 (Closed) IFI 72-09/98201-01 Safety Review Council Proceedings: The licensee's
Procedure GDE-052 "Safety Review Committee Guide," required the safety review
committee to establish a database to track those issues designated as "Immediate
Safety Concerns" or as "Management Attention Items." This procedure required
performance of root cause analysis and the development and implementation of
corrective actions for the issues included in the database. An agenda for the upcoming
October 18, 1999, safety review committee meeting was reviewed during this inspection.
An attachment to the agenda provided a copy of a database of issues entitled
"Assessment Issue Database for Immediate Safety Concerns and Management
Attention Items." This database was controlled by the safety review committee
chairman. A tracking number was assigned to each issue and a responsible person
identified. Six items, all identified as management attention items, were listed in the
database related to document configuration control, training, procedures and design
control limits.
2.2 (Closed) IFI 72-09/98201-02 Maintenance of Decommissioning Records: In
Section 9.4.2 of the safety analysis report, the licensee committed to maintain
decommissioning records in accordance with the Fort St. Vrain ISFSI quality assurance
plan. The safety analysis report required dual storage of records. The licensee was
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storing duplicate sets of the required records at both the Fort St. Vrain ISFSI and at Test
Area North and had implemented the required quality assurance program for the
records. All records required by 10 CFR 72.30 had been reviewed by the licensee and
found to be properly stored. Document PLN-237 "Management Plan for the
Fort St. Vrain ISFSI," Revision 1, was reviewed and determined to contain a complete
list of the required documents. The licensee tracked closure of this issue in Process
Deficiency Report No. 5199.
2.3 (Closed) IFI 72-09/98201-03 Vendor Approval Process: The licensee had performed an
audit of its vendor approval process and had identified a number of shortcomings that
were documented in DOE-Idaho Operations Audit Report No. 98-NSNF-AU-034. As a
result of the audit, the licensee decided to perform a major upgrade of the procurement
system to clarify evaluation and acceptance criteria. The licensee restructured the
procurement system organization in its entirety. Procedure MCP-591, Revision 5,
established facility-wide requirements for qualification of suppliers before a purchase
order or subcontract could be awarded. Additional changes made to the procurement
program included: centralization of the site-wide responsibility for supplier qualification;
re-engineering of the supplier evaluation process such that site-wide roles and
responsibilities were more clearly defined; consolidation of supplier evaluations into a
single site-wide process; clearer definition of the authorized evaluation methods and
criteria to be used; increased controls implemented for the qualified supplier listing
change control process, and consolidation of the qualified supplier list. Following the
organizational restructuring, the licensee provided training to its staff regarding the new
procurement quality assurance process.
2.4 (Closed) IFI 72-09/98201-04 Conflicts between Quality Management Plan and Safety
Analysis Report: Program Quality Management Plan, DOE/SNF/QMP-01, Revision 1,
described the DOE-Idaho quality assurance responsibilities for all DOE spent fuel
activities. The quality management plan provided for the national spent nuclear fuel
quality assurance overview of the various DOE-Idaho sites and served as an
implementing document for quality assurance requirements at NRC licensed facilities.
However, the quality assurance plan contradicted a number of the commitments in the
Fort St. Vrain safety analysis report. For example, safety analysis report Sections 11.3
"Design Control," 11.7 "Control of Purchased Items and Services," and 11.14 "Inspection
Test and Operating Status," all described various provisions for meeting NRC
requirements, but, the quality assurance plan stated in each of these sections that the
national spent nuclear fuel program did not apply to oversight of NRC licensed ISFSIs.
The licensee revised the quality assurance plan such that all sections now contain the
following statement 'The NRC-licensed ISFSI's quality assurance programs will also
comply with and implement the quality assurance plan as applicable. The DOE national
spent nuclear fuel program will perform quality assurance oversight, such as reviews,
audits, surveillances, and assessments of procurement document control at the ISFSIs
to ensure that the ISFSI safety analysis report and the DOE Office of Civilian
Radioactive Waste Management 'Quality Assurance Requirements and Description'
document requirements are implemented."
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2.5 (Closed) IFI 72-09/98201-05 Fort St. Vrain Quality Assurance Program: DOE-Idaho
performed a spent fuel program audit, documented in Report No. 98-NSNF-AU-034,
that identified numerous shortcomings in DOE-Idaho's implementation of the quality
assurance commitments found in the Fort St. Vrain safety analysis report. As a result of
this audit, the licensee made a commitment to develop a quality program plan that
would be specific to the Fort St. Vrain ISFSI and to clarify the quality assurance
requirements of DOE's national spent nuclear fuel program as they relate to
Fort St. Vrain licensed activities. The licensee developed and submitted the quality
program plan, PNL-458, Revision 0, to the NRC on January 4, 1999. The quality
program plan adequately clarified how DOE-Idaho would implement the applicable
requirements of the national spent nuclear fuel program at Fort St. Vrain and the
DOE-Idaho operations that supported the Fort St. Vrain ISFSI. The quality program
plan was revised to include an appendix which translated the requirements down to the
implementing procedures.
2.6 (Closed) IFI 72-09/97207-07 Radiation Protection: The licensee had issued Procedure
MCP-2951 "Fort St. Vrain ISFSI Radiation Protection and Fuel Management Programs,"
which included guidance for the unrestricted release of material from radiologically
controlled areas. Step 4.4.14 of the procedure required all material leaving a posted
radiological area to be surveyed and released in accordance with the limits specified in
Procedure MCP-425 "Survey of Materials for Unrestricted Release and Control of
Movement of Contaminated Material." However, MCP-425 included Attachment A
"Surface Contamination Guidelines" which established release limits above background
levels. NRC requirements in 10 CFR 20.2001 do not provide for releases of material
above background. The licensee has added a note to Procedure MCP 2951
immediately above Step 4.4.14 which stated "The release limits for removable and
surface contamination are any detectable radioactivity above background, not the limits
in MCP-425, Appendix A."
2.7 (Closed) IFI 72-09/97207-19 Auditor Independence: 10 CFR 72.176 requires that audits
be performed by personnel not having direct responsibilities in the areas being audited.
NRC Inspection Report 72-09/97-207 identified that the licensee was performing audits
of its management and operations contractor activities using staff from the same
contractor. Use of staff from the same contractor being audited would not provide an
adequate level of independence to meet NRC regulatory requirements. In their initial
response, the licensee stated that staff used for audits of the national spent nuclear fuel
program activities were organizationally independent from other contractor related
activities and therefore it would be acceptable for DOE-Idaho to continue the practice.
The NRC staff documented it's continued disagreement with this practice in NRC
Inspection Report 72-09/98-201. As a result, the licensee modified Paragraph 4.a.(1) of
Procedure PMP 18.02, "Administration and Conduct of Audits," to include the following
statement: "If the audit is of a DOE-owned and NRC-licensed spent fuel storage
installation, then identify an audit team leader who is not an employee of the
management and operations contractor." The licensee stated that this change was
reflected in all applicable sub-tier procedures.
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2.8 (Discussed) IFI 72-09/97207-22 Quality Assurance Records: NRC Inspection
Report 72-09/97-207 identified that the licensee had not performed receipt inspection of
the fabrication records for the two Transnuclear-Fort St. Vrain spent fuel shipping casks
received from Public Service Company of Colorado during the license transfer process.
A Lockheed-Martin Idaho Technologies Company report dated February 8, 1999, stated
that a team reviewed the records that were provided on the Transnuclear-Fort St. Vrain
shipping casks and found numerous deficiencies. Specifically, the report stated that
numerous records were incomplete or as-built drawings were not the most current
version. DOE-Idaho has begun working with Transnuclear, the packaging designer, to
establish a complete set of records. This issue has been tracked by DOE- Idaho
through process deficiency report Nos. 5198, 5198, and 8831. This issue will remain
open and be inspected at a future date.
3 Exit
The inspectors presented the inspection results to members of licensee management at
the conclusion of the inspection on September 30, 1999. A telephonic exit was
conducted on November 16, 1999, with the final results of the inspection. The licensee
acknowledged the findings presented. The licensee did not identify as proprietary any
information provided to, or reviewed by, the inspectors.
ATTACHMENT
PARTIAL LIST OF PERSONS CONTACTED
Licensee
B. Davis, Quality Assurance Manager
M. Gardner, DOE-Idaho
J. Hagers, Licensing Manager
C. Maggart, Licensing Engineer
Lockheed-Martin Idaho Technologies Company (LMITCO)
T. Borst, Fort St. Vrain ISFSI Manager
S. Chesnutt, Fort St. Vrain Senior Engineer
M. Holmes, Fort St. Vrain Project Assurance Manager
H. Lord, LMITCO Safety Analyst
J. Newkirk, Fort St. Vrain Facility Safety Officer
D. Seymour, Fort St. Vrain Quality Assurance Engineer
Other Contractors
J. Jackson, Utility Engineering Company
J. Leger, Fort St. Vrain Security Supervisor, Burns International Security Services
INSPECTION PROCEDURES USED
60855 Operation of an ISFSI
92701 Follow-up on Open Items
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
72-09/9901-01 NCV Quality Assurance Lead Auditor Qualifications
Closed
72-09/97207-07 IFI Radiation Protection
72-09/97207-19 IFI Auditor Independence
72-09/98201-01 IFI Safety Review Council Proceedings
72-09/98201-02 IFI Maintenance of Decommissioning Records
72-09/98201-03 IFI Vendor Approval Process
72-09/98201-04 IFI Conflicts Between Quality Management Plan and SAR
72-09/98201-05 IFI Fort St. Vrain Specific Quality Assurance Plan
72-09/99-02-00 LER Qualifications of Quality Assurance Auditors
72-09/9901-01 NCV Quality Assurance Lead Auditor Qualifications
Discussed
72-09/97207-22 IFI Quality Assurance Records
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LIST OF ACRONYMS
CFR Code of Federal Regulations
DOE Department of Energy
FSV Fort St. Vrain
ISFSI Independent Spent Fuel Storage Installation
LER Licensee Event Report
NRC Nuclear Regulatory Commission
SAR Safety Analysis Report
SNM Special Nuclear Material
TLD Thermoluminescent Dosimeters
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