IR 05000344/1999004
| ML20206J812 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 05/07/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20206J797 | List: |
| References | |
| 50-344-99-04, 50-344-99-4, 72-0017-99-02, 72-17-99-2, NUDOCS 9905120343 | |
| Download: ML20206J812 (29) | |
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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.' 50-344;72-017 j License No NPF-1; SNM-2509 l
Report No /99-04;72-017/99-02 I
Licensee: Portland General Electric C l l
Facility: Trojan Nuclear Plant ]
l Location: 121 S. W. Salmon Street, TB-17 i Portland, Oregon 1 Date::: March 22-25 and March 29-April 8,1999 Inspectors: . Robert J. Evans, P.E., Team Leader Nuclear Materials Inspection Branch j Division of Nuclear Materials Safety
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Timothy J. Kobetz, Project Manager Licensing and Inspection Directorate i Spent Fuel Project Office !
Office of Nuclear Material Safety and Safeguards
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E. Harold Gray, Senior Reactor inspector l Engineering Support Branc Division of Reactor Safety
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Region 1 John E. Whittemore, Senior Reactor inspector. -
. Engineering and Maintenance Branch Division of Reactor Safety Dennis W. Schaefer, Security inspector .
Plant Support Branch Division of Reactor Safety Approved By: D. Blair Spitzberg, Ph.D., Chief Fuel Cycle & Decommissioning Branch Division.of Nuclear Materials Safety Attachments: .1. SupplementalInformation 2. Trojan ISFSI Photographs 9905120343 990507 PDR
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-2- l EXECUTIVE SUMMARY
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Trojan Nuclear Plant I
~ NRC Inspection Report 50-344/99-04; 72-017/99-01 l I
A special team inspection was conducted to independently assess the licensee's readiness to i load spent fuel into an Independent Spent Fuel Storage Installation (ISFSI). In conjunction with 1 the team inspection, Portland General Electric Company (licensee) performed a preoperational,
. dry run test to demonstrate their capability to load a dry cask with spent reactor fuel. The actual . l movement of fuel was scheduled to begin during May 1999. The licensee intends to utilize an )
- ISFSI,'in part, to allow for decommissioning of the spent fuel pool and associated support equipmen The team had several basic inspection objectives. First, the team determined whether the licensee had developed, implemented, and evaluated their preoperational test activities to safely load fuel into a dry cask storage system (referred to as pressurized water reactor (PWR)~ l I
baskets and associated concrete casks) and then transfer the loaded casks to the ISFS Overall, the team concluded that the licensee has developed a program to safely load fuel into the PWR baskets. : Specifically, the licensee has an adequate number of trained personnel to begin fuel handling operations, fuel handling and related support equipment had been installed and functionally tested, procedures had been established for key operations (although some procedures were still in the final draft stage during the inspection), quality assurance / quality !
control oversight had been established, and management command and control responsibilities j
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Next, the team ascertained whether the licensee had developed, implemented, and evaluated a - j
- preoperational test program in order to safely retrieve spent fuel from an ISFSI and transfer the '
c fuel to.another cask or to the spent fuel pool. This evolution would be necessary if a problem were to develop during fuel handling operations. The licensee demonstrated key elements of
' their program during the dry run inspection. Activities demonstrated included cutting of a welded lid and PWR Basket sampling /reflooding prior to unloading operations. Other activities were also demonstrated during a previous inspection on January 18-February 10,1999 (refer to NRC Inspection Report 50-344/99-01; 72-017/99-01). Based on the qualifications of the personnel, completeness of the procedures, and preoperational testing of fuel handling and support equipment, the NRC team concluded that the licensee has the ability to safely remove fuel from a loaded basket / cask and either transfer the fuel to an overpack or to the spent fuel
. pool if it were still available for fuel storag . Finally,~ the team determir.ed whether the licensee has fulfilled all test acceptance criteria and that all deficiencies were or could be resolved prior to receipt of fuel at the ISFSI. The team concluded that the operating procedures correctly reflected the conditions of the license, and the licensee demonstrated that the acceptance criteria was or could be met. The performance
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of the preoperational test demonstrated that key activities (welding, vacuum drying, and helium backfilling) involving the PWR Basket integrity could be performed in accordance with the
- Safety Analysis' Report and Technical Specification requirement ,
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- In summary, the NRC team determined that the licensee had adequately demonstrated implementation of their dry cask storage program. The NRC team did not identify any deficient program areas. The team's conclusions related to specific program areas are as follows:
Preooerational Testina of An ISFSI
- The inspectors reviewed the preoperational test procedures and found the procedures to be in agreement with the requirements established in 10 CFR Part 72, the license, -
Technical Specifications, Safety Analysis Report, and NRC-approved Quality Assurance plan. However, the NRC team identified one potentially deficient vendor procedure, and the team noted that the heavy lift procedures were cumbersome and complex (Sections 2.2,2.3,2.4 and 2.7).
- One non-cited violation was identified related to the lifting of a heavy load to a vertical
. height higher than authorized by a procedure, resulting in an unanalyzed condition. This licensee-identified and corrected problem was reported to the NRC (Section 2.4).
- ' The quality control and corrective action program implementation was adequat Positive attributes included the identification of problems, establishment of procedure hold points, and quality control oversight of work activities. The licensee implemented a problem reporting system, but the licensee did not thoroughly trend these problem reports to identify recurring problems.- Also, a minor issue was observed involving the videotaping of welds. The team determined that the video tapes were of marginal quality as a permanent record. Also, the disposition of one problem report appeared incomplete with regard to the short-term corrective actions. The licensee has taken or committed to take corrective actions to resolve these issues prior to actual fuel handling operations (Sections 2.3 and 2.6).
- Site security was adequate with three minor exceptions involving one battery test failure, welding of two gates, and discovery of a vulnerable area in the ISFSI perimeter alarm system. Adequate compensatory measures (such as posting of security officers) could be implemented until the corrective actions were completed (Section 2.8).
- - Of particular note is the semi automatic welding system. Because of the welding !
equipment and the skill of the craft, the licensee was capable of performing high-quality !
welds (Section 5.3).
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- -The radiation protection staff was noted to be a strength. The staff appeared dedicated to keeping exposures as low as possible (Section 2.2).'
- The inspectors identified a potential operational problem with the area radiation monitors in the fuel building. This program area will be reviewed during a future NRC inspection (Section 2.9).-
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.4 Report Details i. .
1 - Plant Status The licensee submitted an application to' the NRC for a 10 CFR Part 72 license on March 26,1996.- The licensee requested NRC approval to construct and operate an )
l independent spent fuel storage installation (ISFSI). Following an extensive review of the
- application and supporting documentation, the NRC issued Special Nuclear Materials License SNM-2509 to the licensee on March 31,1999. The license allows Portland
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General Electric Company to' store spent fuel assemblies, damaged fuel assemblies,
. and fuel debris in storage basket / concrete cask assemblies on the ISFSI storage pa The use of the ISFSI will allow the licensee to proceed with decommissioning of the -
L spent fuel pool (SFP), pool support equipment, and fuel buildin In the near future, the licensee plans to remove spent fuel from the SFP and load the 1 fuel into PWR Baskets. Each basket is a stainless steel, welded container designed for storage and transportation of spent fuel and fuel debris. The PWR Baskets were being l
.. fabricated at two offsite locations. Once loaded with spent fuel, each PWR Basket will
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' then be loaded into a concrete cask for storage at the ISFS The licensee plans to construct and utilize 34 concrete casks. The licensee had completed the fabrication of the first five concrete casks by the end of this inspection period. The casks were being assembled at an onsite construction facility.-
l To ensure readiness for fuel handling operations, the licensee pedormed startup testing i of all ISFSI and fuel handling support systems during January-March 1999.: In i anticipation of license receipt and ISFSI operations, the licensee performed a full scale l preoperational, dry run test of all equipment during March 29-April 8,.1999. This test was conducted, in part, to demonstrate the readiness of the equipment, procedures, and
- . personnel to be used for transferring fuel from the SFP to the ISFSI storage pad. Actual movement of fuel was scheduled to begin during May 1999 following receipt of the first
. PWR basket assembl . Prooperational Testing of an ISFSI (60854)
i 12.1- Insoection Scope
~ The NRC team independently ascertained whether the licensee was ready to load spent
- fuel into the ISFSI or retrieve spent fuel from the ISFSI if a problem were to develop with a PWR basket / concrete cask assembly. Program areas specifically reviewed by the team included fuel handling operations, preoperational test procedures, personnel
' training and qualification, lifting of heavy loads, quality assurance / quality control activities, ISFSI security control, and radiation protection activitie ~ Performance of the Preoperational Test-License SNM-2509, Condition 9, states that the licensee shall adhere to the statements,
. representations, and conditions of the Technical Specifications (TS) and the Safety
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Analysis Report (S R) dated March 26,1996, as supplemented. Section 9.2 of the SAR states that prior to operation of the Trojan ISFSI, preoperational tests will be performe The licensee conducted an integrated, dry run test of all fuel handling support equipment during March 29-April 8,1999. The dry run was designed to accomplish the following goals: (1) demonstrate the functionality of all equipment, (2) test and refine the procedures used for loading and unloading activities, and (3) train and rehearse licensee personnel before actual movement of spent fue >The licensee performed the dry run using a mockup PWR basket, the actual transfer ,
, cask, a recently constructed concrete cask, and all support equipment that will be used j during actual fuel handling operations. The licensee did not handle any spent fuel ;
during the dry run. The licensee used both approved procedures as well as draft l procedures. The Fuel Handling Procedure FHP 50-03," Loading and Placing Concrete l Cask into Storage," was in draft form during the test. The licensee performed the test l with this procedure as an attachment to a maintenance reques '
The management oversight / command and control functions were clearly established in the licensee's program. Key positions in the organizational structure had been filled with responsibilities clearly established. Two work crews were utilized by the licensee during the dry run.~ The crews had completed an intensive training program. During the dry run itself, shift turnover briefings were performed at the beginning of each shift to keep the crews informed with up-to-date information. Subjects discussed during the brie'ings included work status, radiological and personnel safety hazards, and recently identified
. problems. An adequate level of detail was provided during the shift briefings, including health and safety issues. The team noted that the efficiency and effectiveness of the
- briefings improved over tim Although the actual radiological hazards were minimal, the licensee's radiation protection staff acted as if the equipment was highly radioactive. The radiation protection staff remained focused on their tasks throughout the test. Combined with the j licensee's as low as reasonably achievable (ALARA) pre-planning activities, the I
- radiation protection program was identified as a potential strength in the licensee's fuel handling program.-
The team witnessed most of the functional test. The test included movement of a mockup PWR basket into the fuel building, loading and welding of the basket, transfer of the loaded (simulated) basket from the transfer cask to a concrete cask, and transfer of the concrete cask to the ISFSI storage pad. The test was performed with only minor problems being observed. The problems included the dropping of a tool into the SFP (the tool was later retrieved), video equipment failure, and discovery and correction of operating procedure problems. These types of problems were representative of a
. complex trial program. The licensee used each incident as a learning situatio Corrective actions were taken for each problem as they were identifie Plant equipment was operated in accordance with procedure requirements. The team confirmed that the support systems, in particular the Gap Flush System and the Vacuum ,
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Drying System skids, were being operated in accordance with vendor instructions unless those instructions conflicted with as built plant or operating limitations. The inspectors
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l-6-I noted that the water pumping and vacuum drying equipment (including th )
instrumentation for pumping water, drawing a vacuum, and filling the basket with nitrogen or helium) was designed with input from lessons learned from other site The team reviewed the preoperational test procedures. All test procedures had been developed, although some procedures were still in draft form during the inspection. The procedures reviewed were found to be in agreement with the license commitments. In particular, the procedures were compared to the guidarce provided in Section 5.0, j
" Operations," of the SAR and the applicable portions of 'l S. Contingency plans and j proposed contingency actions had been included in the primary fuel handling Procedure J FHP 50-03. Although the NRC inspectors provided the licensee with some potential j
_ procedure enhancements, overall, the procedures had been adequately drafted and .
reviewed prior to NRC revie In summary, the licensee performed the integrated dry run test without any major problems. Participants in the dry run demonstrated knowledge and understanding of the tasks being performed. Procedures were adequate and were in agreement with SAR and TS requirements. Overall, the licensee demonstrated the capability to handle spent fuelin a safe and controlled manne .3 Review of Activities lmoactina PWR Basket Intearity
. The NRC team reviewed specific, key portions of the preoperational test in detail to ensure that these program areas were in agreement with TS and SAR commitments. In particular, the team reviewed the activities that impacted the containment boundaries, seal integrity, or long term heat removal capabilities of the PWR baskets. The program areas reviewed in detail included the vacuum drying, helium backfilling, welding, and weld non-destructive examination . Vacuum Drying and Helium Backfilling TS Section 3.1 lists the requirements for PWR basket integrity. Limiting Condition for
, Operation (LCO) 3.1.1 lists the limiting PWR Basket shield lid weld helium leak rate, while LCO 3.1.2 lists the limiting PWR basket vacuum drying pressure. TS LCO 3. ,
states that the PWR basket shield lid weld helium leak rate shall not exceed 1X104standard cubic centimeters per second at 13 pounds per square inch-gauge pressure or higher. Also, TS LCO 3.1.2 states that the PWR Basket vacuum drying final pressure shall be equal to or less than 3 millimeters Mercury for at least 30 minute l The equipment, procedures, work control steps, and actual performance of work for the j PWR basket water removal, vacuum drying, nitrogen flushing, and final helium backfilling were reviewed and observed during the preoperational demonstration. The NRC determined that the licensee would be able to meet the two TS LCOs during actual fuel handling operation J l
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The team determined that the procedures to accomplish the fuel basket vacuum drying and helium backfilling operations were substantially complete and well written. The-equipment operators were trained and knowledgeable on the operation of the equipment j
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and were familiar with the applicable work process steps, instructions, and
' documentation requirements. A quality control inspector was involved with the vacuum-drying and gas filling work as it was in progress. During the test, the numerical requirements specified in TS and the SAR for the helium leak rate and the vacuum drying were met by the license The team concluded that the licensee had the ability to achieve the required vacuum j drying and helium backfilling conditions during normal fuel handling operation .3.2 .. Welding of PWR Basket During actual fuel handling operations, the licensee will perform several critical welds on the PWR basket. The welds include the shield lid, structural lid, and access penetration cover plate welds. The team reviewed or witnessed the welding procedures, welder qualification documentation, welder-specific training, performance of welding, and appearance of completed welds to determine the degree or readiness of the welding group to perform these critical weld The licensee used a semi-automatic, flux-cored arc welding process, with 75-percent argon /25-percent carbon dioxide gas shielding and E308L electrodes, as the primary welding technique. The supplementary welding processes were shielded metal arc
- welding and gas tungsten are welding. During normal operations, the licensee intends to use the flux-cored arc welding process on the shield lid and structural lid welds, while the supplementary welding processes will be used on the access penetration cover plate j During the preoperational test, the shield lid was welded to the mockup PWR basket using the semi-automatic welding system. After completion of the weld, a helium leak ,
test was performed in accordance with the applicable procedure.- The test confirmed 1
.that no detectable leakage was occurring past that weld The preparation and conduct of the helium leak test were found to be well designed, properly planned, and adequately conducted by qualified individual The team discussed the work to be performed with the welders. Also, the equipment used by the welders, such as gas purging, was observed by the inspectors. The welders demonstrated a high degree of skillin welding. The team confirmed that the welders were qualified to the rules of the American Society of Mechanical Engineers Code,Section IX, for the processes they were designated to us ]
i The team observed several dye penetratant tests. The semi-automatic welding process
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was demonstrated to be capable of producing a weld surface that could be inspected using liquid dye penetrant testing without surface preparation other than cleanup at the edge of the weld on the base metal. The welds were observed to pass the non-destructive examinations without having to be repaired or reworked. The NRC team noted that the shield lid, structural lid, and access penetration cover plate welds were of exceptionally high visual qualit s
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8-The NRC inspectors also reviewed the welders' qualification records. Extensive weld process development and training of the welders had occurred prior to the preoperational test. The team identified that the records had several problem areas or were incomplete. Although these problems were corrected by the licensee prior to the completion of this inspection,'similar issues were identified by licensee auditors during a previous quality assurance audit dated March 18,199 .3.3 Non-destructive Examinations
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l The performance of non-destructive examinations and the qualification / certification of those individuals performing the examinations were observed and reviewed by the team, ,
including the performance of liquid dye penetrant test (PT) and visual inspections. The 1 non-destructive examination process and the conduct of the examiners themselves were compared to the applicable quality control inspection procedure. The team noted that
' the quality control examiners carefully followed the applicable procedure requirement The licensee recorded the as-developed PT surface on video tape. The video taping of .
~ the welds is required by the licensee's procedures. The video tape serves as a permanent record of the final weld quality. The initial attempts to obtain a suitable video
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record of the PT-inspected surfaces were less than adequate. For example, the video
'did not cover all areas of the weld as specified in the applicable procedure. Poor f lighting also obscured portions of the weld as it was being videotaped. Corrective actions planned by the licensee included trial use of different lighting situations and different angles to obtain the best videotape record possibl In summary, the licensee was performing non-destructive examinations in accordance
' with procedural requirements. While the PT and visual examination of welds were-conducted carefully and in accordance with the applicable procedures, the details of the method and criteria for the video record had not been fully developed prior to the dry run test demonstration. The licensee planned to establish an improved video record method and guidelines prior to welding baskets loaded with spent fue ~
2.4 - Heaw Lift Activities Applicatsle modification, corrective action, and maintenance control documents were
. reviewed to assess the licensee's readiness for safely lifting and transporting the heavy
. loads involved with the transfer and storage of spent nuclear fuel. Key personnel were interviewed and the heavy lift procedures were reviewed to assess the licensee's preparation and ability to safely handle the heavy load . Fuel' Building Crane Modification LThe inspectors reviewed Defueled Plant Modification Request No.97-012 which was issued to relocate the fuel building crane bridge limit switches. The need for this modification was identified when the licensee determined that the fuel building crane bridge travellimit switches would not allow for positioning of the crane bridge over the
. centerline of the cask load pit.' The licensee performed a satisfactory safety evaluation to assure that the bridge travel limit could be changed while preserving the original d .:.. _ . . . . . . . . . .
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.. I design basis for the limit. The modified limit switch position did not allow either of the
. two crane hoist hooks to encroach upon the 6-foot minimum distance to the SFP as specified in the Defueled SAR, Section 4.2.1. After the implementation of the -
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modification, the crane bridge's electrical limit of travel was still within the mechanical travel limit stops which were not affected by the modi'icatio In summary, the inspectors determined that the modification had been enrrectly evaluated, designed, and implemented while preserving the design basis specified in the licensee's Defueled SA .4.2 L Licensee Event Report 99-01 During late February 1999, the licensee attempted to perform a full load test of the
' ISFSI transfer cask in accordance with Maintenance Request 18677. On or about
- February 25,1999, the licensee lifted the loaded transfer cask (with test weights installed) about 2-3 feet above the fuel building's 93-foot elevation floor to facilitate
- radiation protection personnel taking a swipe survey of the cask bottom. At that time,
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the transfer cask was suspended over the cask load pit which was dry. The cask was then lowered and moved out from the cask load pit area. Personnel performing the lift -
were not aware at the time that a 7.5-inch to 1-foot height restriction was applicable for the transfer cask over the cask load pit. The 7.5-inch limit is applicable when the
, transfer cask is loaded with fuel and suspanded over the cask load pit, otherwise, there is a general 1-foot maximum lift limit whenever the transfer cask is not loaded with fue Maximum load heights for preserving SFP and fuel building integrity in the event of a
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dropped load had been determined through analysis for the safe load path throughout
- the fuel building for various loads. These height restrictions were documented in Attachment 2 of Procedure Trojan Plant Procedure (TPP) 14-9," Control of Heavy Loads," Revision 5. The procedure also specified the travel path leeway and placement of temporary and permanent impact limiters in order to remain within the analyzed
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condition for the dropping of heavy loads within the fuel buildin In addition to the Control of Heavy Loads procedure, the ISFSI Rigging Plan referenced attachments and other procedures in order to document the limits that need to be observed during load handling performance. The ISFSI Rigging Plan was not in effect when the event occurred as the work was being performed under Maintenance Request 18677 which contained a specially developed procedure for loading the test weights and conducting the test. The maintenance request provided work instructions
.. to install test weights in the ISFSI transfer cask and to perform a load test of the cask and the lifting system in the fuel building. The specified lift / travel path was from the fuel building hoistway to the 93-foot elevation floor, along a predetermined safe load path to the Decontamination and Assembly Station, and then to the cask load pi When the licensee became aware that they had lifted the loaded transfer cask higher
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than the procedural limit over a dry pit, the licensee issued Corrective Action Request
' 99-0012 on February 26,1999.
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-10-The NRC team performed a followup review of this incident. The inspectors noted the
- work instructions were complex and cumbersome. For example, the height restrictions to be observed by the crane operatcrs during the performance of the maintenance request were not contained in the procedural steps, instead, the maintenance request referenced the ISFSI Rigging Plan, which was a draft document at the time. Further, the caution note related to the lift height and safe load path restrictions was placed third in a list of three cautions, and the caution was located two steps prior to where it needed to be. The inspectors also noted that the first two caution statements to verify crane stops were functional and ensure the cask and lifting yoke were free of loose parts prior to movement were actually performance steps and not caution statement Other procedures appeared incomplete or potentially confusing in regard to providing the lift height restrictions. The inspectors reviewed draft Fuel Handling Procedure FHP 50-03," Loading and Placing Concrete Cask into Storage." This procedure was the master procedure that will be used by the licensee to transfer fuel from the SFP to the concrete casks. However, Procedure 50-03 also referred the user to other documents or attachments to determine the height restriction for all initial lifts such as from the crane bay floor, decontamination and assembly. station, or the cask load pi The TS for Possession-Only License No. NPF-1 for the Trojan Nuclear Plant, Section 5.7.1.1, states that written procedures shall be established, implemented, and maintained for procedures applicable to the safe storage of irradiated fuel. The ISFSI Rigging Plan is a specific heavy load control procadure which incorporates the requirements of the Trojan Plant Procedure for Control of Heavy Loads (TPP 14-9).
' Procedure TPP 14-9 and the ISFSI Rigging Plan restricted the safe load path lift for a
- loaded transfer cask to 7.5 inches above the 93-foot floor elevation in the fuel building,-
in part, to maintain the structural integrity of the fuel buildin Contrary to the above, on or about February 25,1999, the licensee lifted the loaded transfer cask about 2 feet above the 7.5 inch and the 1-foot limits during cask movement operations over the cask load pit. Although the cask was not loaded with fuel at the time, the incident resulted in a potentially unanalyzed condition, in part, because the cask ic ad pit did not contain an adequate amount of water to minimize the impact loading of the pit. Further, Procedure TPP 14-9 did not adequately require water in the pit as part of the impact-limiting design for a test-loaded weight or fuel loaded transfer
. cask movement over the cask load pit. Therefore, the licensee's failure to fully
' implement a site procedure and the licensee's failure to adequately establish a site procedure were identified as two examples of the licensee's violation of TS 5.7. (NCV 50-344/9904-01).
This Severity Level IV violation is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective
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. action program as Corrective Action Request 99-0012. The licensee concluded that the F causes of the incident included inadequate training, personnel error, and inadequate
- procedures, although the NRC team concluded that complex and cumbersome procedures were the primary cause of the incident. Corrective actions taken or proposed by the licensee included revision of the applicable procedure and ISFSI Rigging Plan, personnel training, and issuance of a Corrective Action Request. The
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licensee subsequently submitted Licensee Event Report 99-01 to the NRC on March 29, 1999, regarding this' event.-
2.4.3 Corrective Action Request 99-0013
' Corrective Action Request 99 0013 was initiated when an engineering review revealed that the. fuel basket shield lid retainers, part of the transfer cask, were not sufficiently -
strong to perform their design function of holding the basket lid in place in the event of loaded transfer cask tipover. A detailed analysis by licensee's engineering revealed that the retainers could not resist the design load. At the end of the inspection period, the licensee was initiating a modification to strengthen the retainers. The licensee modified the retainers immediately after the conclusion of the inspection. Failure of the retainer could result in the spilling of spent fuel assemblies during a basket tipover even ' Trainina and Staffina for ISFSI Ooerations Training requirements are specified in Section 7.3 of the Defueled SAR and Section of the ISFSI TS. Training is conducted in two broad categories; the Certified Fuel Handler Training Program was for operators handling fuel in.the fuel building and the ISFSI Specialists Training' Program was for operators of the equipment on the ISFSI storage pad. The NRC team reviewed the licensee's training programs during the
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inspection. The two training programs were conducted in accordance with the 10 CFR
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Part 50 and Part 72 license requirements and an adequate number of individuals were trained and certified to perform the preoperational tes During fuel handling operations, the licensee plans to utilize four ISFSI fuel loading crews trained under the Certified Fuel Handler Training Program. Each crew will be led by an ISFSI supervisor and will consist of a technical director, ISFSI loading specialists, security and radiation protection support personnel, welders, and quality control personnel. Two crews and all four ISFSI supervisors participated in the preoperational test. At the time of the inspection, all four ISFSI supervisors had been certified. The licensee plans to complete the training of all four crews prior to fuel handling operations.
,_ , The Trojan site training organization had developed a training and qualification program
~ for fuel loading crews based on a systematic approach to training. This approach mandated that the licensee: perform a iob task analysis; icientify the elements of each l task within the analysis; develop learning objectives from the identified elements;
- develop classroom and practical training to teach the learning objectives; develop testing to assure that students have mastered the learning objectives; and perform an
. evaluation of the prcara The inspectors reviewed a small portion of the job task analyses and verified that the licensee's methodology had correctly identified task elements, which resulted in the appropriate development of learning objectives, training development, and testing methodology. The licensee had also developed a matrix to indicate which learning objectives would be mastered by the various fuel loading crew position .
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,o-12-Training of the ISFSI specialists was incomplete at the time of the inspection. Currently, eleven individuals were being trained as ISFSI specialists. The licensee planned to
- complete the training program prior to fuel handling operations. These individuals will be used to perform routine surveillance and monitoring of the concrete casks being
' stored on the ISFSI storage pad.- Corrective Action and ISFSI Problem Reoort Proarams -
Procedures and documents related to the licensee's Corrective Action Program and ISFSI Problem Reporting (IPR) Program were reviewed. Interviews with managers and staff were conducted conceming the use of both programs for identifying problems with the ISFSI precperational testing program. Further, the programs were reviewed to assess whether concerns previously identified by the NRC and documented in NRC
- Inspection _ Report 50-344/99-01;72-017/99-01related to the licensee's Corrective Action Program had been resolved. The evaluation of the licensee's program included detailed review of Trojan Plant Procedures TPP 29-12, " Independent Spent Fuel Storage Installation Problem Reports," Revision 0, and TPP 17-1; " Corrective Action Program,"
Revision In response to the findings identified during the previous NRC inspection, the licensee established IPRs as a mechanism for its staff to identify problems concerning the ISFS Specifically, the purpose of the IPR was to promptly identify, track, evaluate, and resolve minor problems that did not rise to the threshold of a corrective action request or other deficiency reports used by the licensee. During the inspection, the licensee's ISFSI IPR system was reviewed to ascertain whether the program was being used to document potential problems and to ensure that followup reviews were being conducted by the licensee to adequately resolved the documented problem The IPR process was placed into service during February 1999. At the end of the inspection period, the team noted that the licensee's staff had generated about 140 IPRs. This demonstrated that the program was being utilized by the license The inspectors reviewed IPR Nos. -004, -011, -013, -018, -020, -024, -037, -059, -061,
-62, -063, -079,'-092, and -102 in detail during the inspection. The review found that the 1
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licensee was appropriately using IPRs to identify problems concerning the ISFSI. In 1 addition, the review found that license management reviewed each IPR and, when
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Lappropriate, initiated a corrective action request for problems which reached the 1 threshold described in Procedure TPP 17- . The NRC t'eam identified that the Operations Manager was not reviewing IPRs for
- trends as recommended _ by TPP 29-12, Paragraph 4.7.1. In addition, TPP 29-12 did not describe a method for documenting the trending of IPRs. The trending categories of hardware deficiency, program deficiency, and welding program deficiency were too broad to provide meaningful trending information and were not routinely used during the resolution of an IP During the review of IPR Nos. -004, -013, and -092 the inspectors identified a potential trend of foreign material exclusion control deficiencies that the licensee was treating as
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-13-isolated incidents. While the inspectors did not identify that a significant negative trend
. existed with foreign material exclusion, the inspectors did identify that the licensee's foreign material exclusion program may warrant additional attention by the license Overall, the proposed solutic,ns to the IPR problems appeared effective for resolving the stated problems, with one notable exception. IPR No. 62 was issued on March 10, 1999, to document the presence of cloudy water in the PWR basket. The PWR basket
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was in the cask load pit at the time. The evaluation noted that the probable cause of the problem was the result of a chemical reaction between the " Carbo Zinc 11" coating in the basket and the boric acid in the fuel transfer canal water. This type of chemical .
reaction typically results in the generation of hydrogen gas bubbles. Since the actual baskets were to be coated differently from the prototype basket, the IPR concluded that no action was required and the IPR was closed ou The team concluded that this IPR did not address the short-term problems related to the potential for a hydrogen burn during the welding activities. The licensee planned to weld the basket lids during the preoperational test. However, the licensee had not taken effective corrective actions concerning the hydrogen generation to ensure worker safety during the welding process. Although the licensee had a requirement for establishing a purge, the procedure did not specify a particular purge flow rate or require hydrogen monitoring. In response to the NRC's concerns, the licensee revised the applicable welding procedure prior to the first weld to include specific instructions for establishing a
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specific purge flow rate into the PWR Basket void space and to monitor for hydrogen in the area of the weld The team also noted that a hydrogen burn had occurred under similar circumstances during 1996 at another facility. The licensee was aware of the incident but had not adequately addressed the issue in their procedures. In response to the NRC team's -
concerns, the licensee updated the applicable procedure prior to the first weld. The licensee subsequently determined that a potential cause of the inadequate IPR-62 problem analysis was related to their failure to implement a design change into their procedures. The prototype basket design had changed after the development of the licensee's procedures, but the applicable procedures were not updated prior to preoperational testing to take into account the PWR basket design chang In summary, the licensee had developed and implemented a program to identify and document ISFSI-related problems and concerns. Although some problem areas were
. identified, overall, the team d' etermined that the IPR process was an asset to the license .
. .Q_q.n_ crete Cask Construction
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During the inspection, the team observed the construction of two concrete casks and reviewed documentation related to the construction and operation of the two casks. The fabrication process was observed to determine the quality of the completed casks and to ensure that the casks were being constructed in accordance with SAR requirement P
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-14-The casks were being constructed at an onsite fabrication facility located adjacent to the ISFSI storage pad. Concrete Casks No. 4 and 5 were completed during the inspectio Work control packages, cask drawings, quality control inspection points, and final !
conditions prior to casting were reviewed. The team noted that the concrete casting process included in-process testing of the concrete batches prior to use and preparation 1 of break cylinders for testing concrete properties such as strength. Overall, the team j noted that the licensee was constructing the casks in accordance with the SAR j requirement !
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The team reviewed selected documentation related to the concrete cacks. One potential problem was identified involving a discrepancy between the vendor's and the licensee's instruction for performing concrete inspections. Paragraph 1.3.1 of the vendor's specification PCC-SP-004, Revision 1, required the concrete surface to be free i of imperfections greater than %-inch in length or width and less than %-inch in depth, i However, the licensee's ISFSI Procedure TIP-09, Revision 0, paragraph 6.2.1, required defects greater than % inch in diameter and greater than %-inch in depth be identified j for further investigations. The team observed that concrete casks Nos. 4 and 5 had ]
surface cracks greater than %-inch in length, but the depth of the cracks could not be I easily determined. In summary, while the observed cracks were not likely to be of f functional significance, the vendor's specification was noted to be in disagreement with !
the licensee's procedures for performing concrete cask inspection At the end of the onsite inspection, the licensee issued a Non-Conformance Report to document the NRC-identified concerns regarding the concrete surface imperfection The licensee's vendor subsequently revised the specification wording to agree with Trojan ISFSI Procedure TIP-09. Next, a new section was added to the specification which required that an evaluation be performed on all shrinkage cracks in accordance with American Concrete Institute guidance. If unacceptable cracks or surface imperfections were found during this evaluation, then a Non-Conformance Report would be issued. Finally, the NRC team noted that all surface imperfections should be conditioned (patched) by the vendor or the licensee as part of the concrete finishing process. Therefore, the NRC team determined that the licensee's actions taken in response to the team's findings were acceptabl The team also reviewed selected procedures related to storage of the concrete casks on the ISFSI storage pad, including the thermal monitoring program procedure. The long term storage of casks on the ISFSI storage pad includes measurement of the increase in temperature of air as it flows through the storage cask. Thermal monitoring is required by TS Section 5.5.3. A high temperature differential would be indicative of a potential problem. The equipment and procedures for long term temperature monitoring I I
were reviewed with the responsible licensee engineer. The licensee demonstrated several methods that will be used to monitor the ambient and cask discharge temperatures, including bac' up methods. The team did not identify any items or concerns in this program ara : i t
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- i ISFSI Safoouards Activities ;
D0 ring the inspection, the licensee had not initiated storage of spent fuel in the ISFSI -
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- protected area and the ISFSI protected area had not yet been initially secure Therefore, portions of the Security Plan (Revision 1 dated January 8,1999) were not '
_ : required to be operable. The NRC team assessed whether the licensee was ready to activate the Security Pla .8.1' , Conduct of Security and Safeguards Activities : Access A'uthorization .
. The access authorization program was reviewed to determine compliance with the requirements of the Security Plan. The areas reviewed included the review of seven
- background investigation files for individuals presently granted unescorted access to the site. The inspector reviewed records and conducted interviews to determine the p* ; adequacy of the program. The inspector also reviewed information conceming the licensee's verification of employment history, criminal history, and the character and reputation of the applicants before granting individuals unescorted access to the sit Background investigation screening files were complete and thorough. Personnel administering the program' performed their duties in an excellent manner. Through a review of the licensee's policies and procedures, the inspector determined that the access authorization program contained specific guidance necessary to implement the progra In summary, performance in the access authorization area was very good. An effective
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access authorization program was established to grant individuals unescorted access to
- the sit Alarm Station and Communications Thh alarm station and the security communication capabilities were inspected to determine compliance with the requirements of the Security Plan. The areas inspected
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- included the requirements'and capabilities of the alarm station, protection of the alarm
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station, systems security, operability of radio and telephone systems, and the capability to effectively communicate with the local law enforcement agencies through both communication system Through observations and interviews, the inspector verified that the central alarm
- station (CAS) was a separate stand-alone protected area located in the access control
- facility. The CAS was equipped with appropriate alarm, surveillance, and communication capability.':The alarm station was continually manned by an alarm station operator whose duties dia not interfere with the execution of assessment and response' functions.' The inspector also determined that all of the licensee's access
- control and intrusion alarms were monitored from the CAS and that all alarms also annunciated in a nearby secondary alarm station. Within the CAS and secondary alarm station, an indication was provided of the status of all alarms and alarm zones. Alarm n
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communication with each watchman on duty, and capable of calling for assistance from j the local law enforcement authorit The inspector verified that the licensee had effective radio and telephone systems capable of meeting communication requirements. Each watchman was equipped with a -
portable two-way radio. The CAS had both a base radio system and a commercial telephone to maintain contact with local law enforcement authority. The licensee -
maintained an adequate number of portable radios for use by the watchme . Communication checks with the local law enforcement authority were conducted at least once every 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> In conclusion, an effective alarm station and security radio communication system was being maintained. Alarm station operators were alert and well trained. An adequate number of portable two-way radios were available for watchme Protected Area Access Control of Personnel, Packages, and Vehicles j
- The access control program for personnel, packages and vehicles was inspected to l
determine compliance with the requirements of the Security Plan. Through #
' observations,~ interviews, and a review of procedures, the inspector determined that i upon securing the barrisrs (fences) around the ISFSI protected area, the licensee will l
- have adequate provisions in place to ensure that only authorized personnel gain unescorted access to this area. Persons having a need to enter the ISFSI protected area, but not authorized unescorted access, will be escorted within the protected are Authorization for unescorted access to the ISFSI protected area shall be verified using picture identification and an access list approved by the ISFSI manage The inspector also verified that the licensee had adequate provisions in place to search all personnel, packages, and vehicles for explosive devicer pn >r to granting access into the ISFS1 or the CAS protected area. The search was to bv.anducted by a physical search (pat down) or with the use of equipment designed to detect explosives. No vehicles shall remain inside the ISFSI protected area during periods when there is no personnel activity, unless authorized by the ISFSI manager and the vehicle key is removed and controlled by security.-
In summary, the licensee has provisions in place to implement a thorough program for searching personnel, packages, and vehicles prior to entering the ISFSI protected area, and for searching personnel and packages prior to entering the CAS. These provisions
.will be implemented and will remain in effect prior to storage of spent fuel inside this are '.8.2. Status of Security Facilities and Eauioment Testing and Maintenance
.The testing and maintenance program was reviewed to determine compliance with the
' requirements of the Security Plan. Through interviews with ISFSI staff, the inspector
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determined that repairs to security equipment were completed in a timely manne Through review of testing records, the inspector verified that security equipment and tamper alarms were performance tested as required by the Security Plan. The security i systems and support equipment were checked for operability weekly and at the !
beginning and end of each interval used for security. Overall, the testing and maintenance of security equipment were completed in a timely manner and were
. properly documente l Protected Area Barrier and Detection Aids : I
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. l The protected area physical barriers and detection aids were inspected to determine I compliance with the Security Plan. The areas inspected included the features of the ISFSI and the CAS protected area barrier and the design and capabilities of the detection aids system The inspector determined that the ISFSI area was surrounded by an adequate protected area fence. Additionally, a second (debris) fence was installed outside of the protected ;
area fence. An isolation zone on the interior and exterior of the ISFSI protected area j fence had been established. The licensee had adequate provisions to secure the two ISFSI fences prior to the initial storage of spent fuel. A protected area barrier had been
' established around the CAS. The ISFSI and the CAS protected areas were being monitored by an active intrusion detection system. The inspector also determined that the licensee's weekly tests of the protected area barriers were performance based to ensure that system failures were discovered and correcte The licensee had initiated a Maintenance Request (No.19092) to spot weld components of the vehicle and pedestrian gates located in the two ISFSI fences. Spot welding th gate components will eliminate the current deficiency of being able to use hand tools to defeat and bypass the ISFSI fence !
Section 1.2 of the Security Plan requires that the ISFSI protected area fence to be )
alarmed. During the inspection, the licensee performed functional tests of each alarm
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zone of the ISFSI and the CAS protected areas. All attempts to intrude into the 1 protected areas were detected and all alarms annunciated in a continuously manned I alarm station, with two exceptions: (1) two alarm zones around the ISFSI were in
" continuous alarm" and could not be tested, and (2) the licensee defeated one alarm i segment by jumping over a detection zone.- i The licensee stated that these items would be corrected or that adequate compensatory measures would be posted prior to storing spent fuel inside the ISFSI protected are Licensee actions to correct the above deficiencies of the ISFSI protected area barrier and detection aids will be tracked as an inspection followup itern (IFl 72-017/9902-01).
In summary, a good protected area barrier and detection system was in place that would provide delay and detection to individuals attempting unauthorized entry into the protected areas of the ISFSI and the CA <
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' The' assessment aids were inspected to determine compliance with the Security Pla The areas inspected included the closed-circuit television (CCTV) monitors located in the CAS and the CCTV cameras located at the ISFSI and CAS protected areas. The inspector observed the assessment aids and determined that the system was effectiv The CCTV cameras at the ISFSI and CAS protected areas were properly positioned and each CCTV camera produced a clear image on a monitor in the CAS. Prompt ;
. maintenance support was being provided to ensure that system problems were
. corrected in a timely manner. Overall, assessment aids provided very good assessment f at the ISFSI and CAS protected areas and produced a clear image on monitors in the . 1 security alarm statio . Compensatory Measures !
, I Compensatory measures were evaluated to determine compliance with the ]
- requirements of the Security Plan, including provisions for deployment of compensatory measures and the effectiveness of those measures. The licensee had developed quick reaction lists to deploy compensatory measures in a manner consistent with the
- requirements in the physical Security Plan. The ISFSI personnel available for assignment to compensatory security posts were properly trained for those dutie ' Compensatory measures were effectively defined and ISFSI personnel were well trained on the compensatory measure requirement Security System Power Supply
. The security system power supply was inspected to determine compliance with the -
Security Plan. Section 1.6.3 of the Security Plan requires specific security equipment to !
be supplied with an uninterruptible power supply (UPS) system capable of providing at I least a certain number of continuous hours of operation. During the inspection, the licensee conducted load testing of the UPS systems. The licensee determined through
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testing that each of the UPS_ systems performed as required, except one. One UPS system did not operate on its backup battery for the required le'n gth of time. The licensee stated that this deficiency would be corrected prior to storing spent fuel inside
- the ISFSI protected area. This issue will be tracked as an inspection followup item (IFl
~ 72-017/9902-02).
In summary, the security backup power supply system performed adequately, with the I exception of one UPS battery.;
. f.' - - Security Locks, Keys and Combinations The licensee's locks, keys, and combinations were inspected to determine compliance
- . with the physical Security Plan. ' Through a review of lock and key procedures and records, the inspector determined that inventories were completed as required. The
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records indicated that the locks and keys were rotated annually or changed when employees who had access to security locks and keys.were terminated.- Security of the
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in conclusion, a good lock and key control program was being maintained and
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implemente .8.3 Security and Safeauards Procedures and Documentation Security Program Plans and Procedures -
The licensee's ISFSI Security Plan and' implementing procedures were inspected to determine compliance with the requirements of 10 CFR 72.44(e) and 10 CFR 72.18 The ISFSI Security Plan incorporated the ISFSI security training and qualification plan and contingency response pla The inspector determined from a review of security plans and procedures and interviews )
with licensee ISFSI personnel that changes to the licensee's NRC-approved Security q
. Plan did not decrease the effectiveness of the Plan. Plan changes had been submitted 1
- in accordance with NRC requirements. The licensee was maintaining an effective management system for the development and administration of procedures and had a process to verify that changes to the procedures did not reduce the effectiveness of the licensee's security progra Iln summary, Security Plan changes were being submitted in accordance with NRC requirements and changes had not decreased the effectiveness of the plans. Security procedures were consistent with the Security Pla Security Event Logs The safeguards event logs and security incident reports were inspected to determine compliance with the requirements of 10 CFR 72.74,10 CFR 73.71, and the Security
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. Plan. The inspector reviewed the safeguards event logs from March 1998 to March 5, j 1999. The licensee met regulatory requirements regarding the reporting of security i events.' The necessary records were available for review and were maintained for the 1 time required by regulations.
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. ISFSI staff was correctly reporting security event ;
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l' Recponse Capabilities 1 Response capabilities were inspected to determine compliance with the Security Pla The licensea's contingency plan was included in Chapter 1 of the Security Plan. The licensee maintained adequate on-duty personn'el (watchmen) to respond to an even The inspector determined that the on site ISFSI response force was capable of meeting the response requirements of the Security Plan.
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, i The licensee had available offsite response from two different law enforcement
- agencies. The Columbia County Sheriff's Department was the primary responding
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agency. A December 16,1998, letter from the Sheriff's Department specified the response time and the number of armed responders available to respond to the ISFSI protected are Overalllthe'onsite and offsite response capabilities met the requirements of the Security Pla .8.4 Security and Safeauards Staff Trainina and Qualification
- The licensee's security training and qualification program was inspected to determine compliance with the requirements of the Security Plan. The licensee's security training and qualification plan was included as Appendix C to the ISFSI Security Pla The inspector observed ISFSI staff during the performance of their duties. The observed staff personnel demonstrated good knowledge of the procedural requirements for the tasks they were performin The ISFSI management had conducted all required training in accordance with the approved Security Plan. The training was required every 12 months. The inspector also '
reviewed the ISFSI staffs' medical records and determined that the medical evaluations-were conducted as required by the Security Pla In summary, training of ISFSI personnel had been conducted in accordance with the .
Security Plan. ISFSI staff personnel demonstrated very good knowledge of the procedural requirements for the tasks they were performing. Medical evaluations were l current.-
2.8.5 Security Oraanization and Administration Management Suppor The effectiveness and adequacy of management support for the ISFSI physical security program were inspected. The inspector interviewed ISFSI personnel and determined from their comments that licensee management of the ISFSI organization was very good. The security program was being implemented by a trained and qualified ISFSl
~s taff.' All members of the security organization had a clear understanding of their duties and responsibilitie In summary, management support for the licensee's security program was excellen ' 1 Staffing Levels-E Staffing of.the ISFSI shifts was evaluated to determine compliance with the Security Plan.;The inspector determined from discussions with ISFSI personnel and reviewing the shift personnel rosters that there was an adequate number of ISFSI personnel
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always available to meet the number specified in the physical Security' Plan. On-shift security staffing of ISFSI personnel was properly maintaine .8.6 - Quality Assurance in Security and Safeauards Activities The audit of the licensee's physical security program was reviewed to determine
. compliance with the requirements of the Security Plan. The inspector reviewed two of the licensee's audits of the ISFSI program. The audit team were independent of plant ISFSI management. It was determined that audit team personnel were well qualified and the audits were performance-based. The security department promptly resolved all identified deficiencies / findings. The audits were comprehensive and of excellent qualit . Miscellaneous Security and Safeauards issues / Year-2000 Comoliance Testina Year-2000 Compliance Testing During this inspection, the licensee stated that on March 26,1999, Matrix Systems, Inc.,
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had completed their Year-2000 testing of the following types of security system
- equipment installed at the Trojan Nuclear Plant: (1) RMS Host Computer,
-(2) XWindows Computer, and (3) Controlled Access Test Readers MX 540, MS 570, MS 125 input / Output Reader, and the Biometrics Hand Reade As a result of testing, Matrix Systems determined that all equipment, except the Local Area Network Workplace 5.0 program for Windows, was Year-2000 compliant. - Matrix Systems provided the licensee with a Year-2000 update disk for this program. The licensee's installation of this disk will make the Workplace 5.0 program compliant with Year-2000 concerns. The licensee intends to install this disk prior to July 199 .9 - Other issues
L 2. Area Radiation Monitors Two area radiation monitors (ARMS) provide criticality alarms in the fuel building spent fuel handling and storage areas. Operability requirements are specified in Section 5.6.1.3.1 of the Defueled SAR.' During a previous inspection, an NRC inspector noted that ARM-12 was partially shielded by an equipment skid. Since the previous l
inspection, the licensee relocated the skid to a different position on the fuel building 93-foot elevation. The inspector also noted that the expected radiation levels during movement of the loaded transfer cask near the ARMS may be greater than the ARMS'
alarm setpoints, meaning that the alarm would activate each time a cask was transported by the alarm During the preoperational test, the (draft) Fuel Handling Procedure FHP 50-03, " Loading and Placing Concrete Cask into Storage," provided direction to render the ARMS inoperable. However, licensee representatives later stated that a system modification was being proposed to disable the local alarms only. This issue will be tracked as an inspection followup item (IFl 72-017/9902-03).
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.2. Prime Mover Soeed Sensor -
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The licensee plans to use air pads and a motorized vehicle (prime mover) to move the concrete casks between the ISFSI sto. rage pad and the fuel building. Section 5.1.1.3 of -,
the SAR states that administrative controls will limit the transport speed to less than -
2 feet per sm:ond.~ The method used by the licensee to control speed was briefly .
~ reviewed by the teams At the time of the dry run, the licensee had not installed a speed sensor in their -
motorized prime mover. The licensee was using graduated marks on a wheel of the prime mover to monitor concrete cask speed by timing the speed of the wheel.' The licensee notified the NRC team after the completion of the onsite inspection that a speed sensor has since been installed in the prime mover. The speed sensor will -
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provide a better method of monitoring concrete cask speed below the SAR limi .10 Conclusions
. The' ISFSI preoperational test process provided reasonable assurance that the licensee's site ISFSI team was prepared to safely initiate the dry fuel storage proces ,
. Of particular note was the licensee's semi-automatic welding system and the radiatio protection program personnel. Both were considered to be licensee strengths. Fuel handling procedures had been developed. The procedures had incorporated SAR and TS requirements. The licensee operated the equipment in accordance with site procedures and vendor recommendations. Training was provided to the test performers
' and was conducted in accordance with the license requirements.' No major problems were encountered by the licensee during the preoperational test.. Further, no major test >
. deficiencies were identified by the NRC team.:
The licensee had developed a program to ensure the integrity of the PWR baskets, Including welding, drying, and backfilling. The licensee demonstrated that they had the' l capability to meet the applicable TS and SAR operational parameters. The plans and
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j equipment for long term temperature monitoring of the PWR basket and concrete casks l were found to meet SAR, TS, and procedural requirements. Further, the team noted ;
that the licensee was constructing the concrete casks in accordance with the SAR
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requirements, although one.potentially deficient vendor specification was identified by -
the tea : With regard to the quality assurance / quality control program, the licensee had ,
established an adequate program for identifying conditions adverse to quality. The licensee had made improvements in identifying problems associated with the ISFS .1
- IPRs.were routinely initiated for problems encountered during the pre-operational testing
' of the ISFSI. However, trending of conditions adverse to quality remained weak. In
' addition, a weakness was identified related to the videotaping of completed welds. . The licensee indicated th'eir intent to take appropriate corrective actions prior to actual fuel loading operations.L The team identified one problem report that appeared to be inadequately dispositioned. The licensee took prompt and effective corrective action
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u i0-L -23-l l i The licensee had developed a program for controlling heavy loads, although the team concluded that the work instructions were cumbersome and complex. These complex l l
work instructions contributed to a licensee-identified violation of NRC requirements.
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The NRC performed a thorough review'of the licensee's security program. Although
. several potential problem areas were identified, including the identification of ~
deficiencies with protected area barriers, detection aids, and a UPS battery power-source, the licensee had corrective actions planned and the licensee appear _ed ready to implement the Security Pla Followup (92701)
3.1 ' (Discussed) IFl 50-344/9901-01: Actions Taken to Prevent Concrete Cask Movement
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off the Edge of the Concrete Storage Pad
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During a previous inspection, the NRC identified a potential problem related to
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preventing a cask from being moved beyond the edge of the concrete storage pad. The i licensee proposed corrective actions were to cut a groove into the edges of the concrete pad which would deflate the operating air pads. A second corrective action was l ' proposed which would establish administrative controls on cask positioning during
! concrete cask movement.
l' During this inspection, ttie NRC assessed whether these proposed corrective actions )
had been implemented. The licensee had cut a %-inch groove into the concrete, but the i
! licensee had initially proposed a %-inch groove. During the inspection, the licensee.
l committed to install the %-inch groove prior to movement of a fuel loaded concrete cask - l
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- onto the ISFSI storage pad. The licensee did not intend to perform a funcfional test
- because of the potential for damage to the air pad ' in summary, since the corrective actions for this issue have not been completed, this IFl will remain ope Exit Meeting Summary i
The NRC team presented the inspection results at the conclusion of the inspection on l ' April 8,1999. - The licensee acknowledged the findings presented. Tt e licensee stated L that some of the contractor's heavy lifting instructions and drawings ware proprietary information and some of the security program information was safeguards-relate O
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!- ATTACHMENT 1 PARTIAL LIST OF PERSONS CONTACTED
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1.icensee i
J. Allison, Heavy Lift Coordinator / Project Engineer )
K. Allison, ISFSI Loading Project Manager j L A. Bowman, Chemistry / Radiation Protection Supervisor l
! C. Brown, Training Specialist
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K. Cox, ISFSI Manager L. Dusek, Nuclear Regulatory Affairs Manager ]
M. Gatlin, Nuclear Security Manager !
D. Gildow, Decommissioning Planning Manager j M. Lackey, Engineering & Decommissioning General Manager l T. Meek, Radiation Protection Manager i J. Mihelich, Engineering Manager
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S. Nichols, Decommissioning Projects Manager i D. Nordstrom, General Manager
- S. Quennoz, Trojan Site Executive & Plant General Manager )
l J. Reid, Quality Assurance Specialist i S. Schnieder, Operations Manager J. Vingerud, Maintenance Manager i
l INSPECTION FROCEDURES USED l l
- 37801 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown l Reactors 60854 Pre-operational Testing of an ISFSI l 71801 Decommissioning Performance & Status Review at Permanently Shutdown -
l Reactors 81001 Independent Spent Fuel Storage Installation (s)
83750 Occupational Radiation Exposure 86750 Solid Radioactive Waste Management & Transportation of Radioactive Materials 92701 Followup 92904 Followup - Plant Support l ITEMS OPENED CLOSED AND DISCUSSED 1 Opened l l
50-344/9904-01 NCV Failure to Establish, implement, and Maintain Procedures l
j 72-017/9902-01 IFl Deficiencies with Protected Area Barriers and Detection Aids 72-017/9902-02 IFl Deficiency with an Uninterruptible Power Supply System 72-017/9902-03 IFl Modification of the Fuel Building ARMS
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50-344/9904-01- NCV Failure to Establish', implement, and Maintain Procedures Discussed 50-344/9901-01' llF Actions Taken to Prevent Concrete Cask Movement off the i Concrete Storage Pad j LIST OF ACRONYMS q i
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ALAR ~ As Low As Reasonably Achievabic .)
ARM Area Radiation Monitor J CCTV- Closed Circuit Television
'CAS Central Alarm Station _ )
CFR . Code of Federal Regulations IFl . -- Inspection Followup item . 4
~ IPR ISFSI. Problem Report 1
- ISFSI - Independent Spent Fuel Storage installation -l LCO Limiting Condition of Operation - l NCV Non-Cited Violation ' 1 PDR- Public Document Room i
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1 P Liquid Dye Penetrant Test PWR- Pressurized Water Reactor SAR Safety Analysis Report SFP' Spent Fuel Pool TPP- Trojan Plant Procedure TS ; . Technical Specification UPS~ ~ Uninterruptible Power Supply LIST OF DOCUMENTATION REVIEWED TPP 12-1, " Nuclear Division Manual Procedure Use and Organization," Revision 2 .
TPP 14-3, " Work Control Process," Revision 11 TPP 14-9, " Control of Oleavy Loads," Revision 5 TPP 16-1,-" Material / Service Procurement and Control Process," Revision 4 {
TPP 18-15," Determining Reportability of Events or Conditions," Revision 5 i
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ISFSI Rigging Plan (Draft)
- FHP 50-03, " Loading and Placing Concrete Cask into Storage" (Draft)
Portland General Electric Audit AP-743 of Security and Fitness-for-Duty, dated May 12,1998 !
- Portland General Electric Audit AP-750 of ISFSI Readiness to Load Fuel, dated March 18,1999 !
Security Event Logs for the period January 1 through March 5,1999 !
, Security training and qualification records on three watch-persons (security officers) i Annual medical qualification records on 5 watch-persons (security officers) i l
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. LIST OF DOCUMENTATION REVIEWED, continued
, Trojan ISFSI Security Plan Implementing Procedure (SPIP) 01, " Security Operations Procedure," Revision 0 .
Trojan ISFSI Security Plan implementing Procedure (SPIP) 02, " Security Screening for Access Authorization," Revision 0 ] 4 Security Operation Instruction (sol)-2, " Roving Patrol / Key-Control / Secondary Alarm Station /ISFSI Protected Area (PA) Access Control," Revision 0 Security Operation. Instruction (SOI)-3,"lSFSI/CAS Protected Area Alarm Testing," Revision 1 ,
Security Operation Instruction (SOI)-4, "Secufity of Cask Transportation," Revision 1 {
Security Operation Instruction (SOI)-5," Central Alarm Station Protected Area Search and
. Access Requirements," Revision 0 Security Operation Instruction (SOI)-6, " Protection of Safeguards information," Revision 0 Security Operation Instruction (SOI)-7, " Quarterly UPS Test," Revision 0 Security Operation Instruction (SOI)-27, " Industrial Area Access Control," Revision 13
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- Security Operation Instruction (sol)-27A, " Key Card Enrollment," Revision 12
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Trojan independent Spent Fuel Storage Installation Security Plan, Revision 1, January 8,1999 l Quarterly UPS Testing Records for the period of June 1998 through March 1999 '
Annual Tamper Switch Test for Security System Records dated November 24,1998
' Weekly Biometric Hand Geometry Reader Testing Records for the period of January through 3 March 1999 1 l
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Attachment 2
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TROJAN ISFSI PROJECT f
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ISFSI Storage P,ad ISFSI Transfer Station i
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ISFSI Transfer Station and three completed Fuel Building operating deck; 93-foot i Concrete Casks elevation; D&AS on left i
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..s 6 Air Compressor for Air Pad System Typical Air Pad used for lifting Concrete Cask
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".; Completed Concrete Cask
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