IR 07200009/2024001

Independent Spent Fuel Storage Installation (ISFSI) NRC Inspection Report 07200009/2024001

ML24129A120
Person / Time
Site:	07200009
Issue date:	05/08/2024
From:	Greg Warnick NRC/RGN-IV/DRSS/DIOR
To:	Michael Brown US Dept of Energy (DOE)
References
IR 2024001
Download: ML24129A120 (13)

Text

May 08, 2024

SUBJECT:

FORT SAINT VRAIN INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) - NRC INSPECTION REPORT 07200009/2024001

Dear Mark C. Brown:

This letter refers to the U.S. Nuclear Regulatory Commissions (NRCs) announced routine inspection conducted on April 16-17, 2024, at the Fort Saint Vrain Independent Spent Fuel Storage Installation (ISFSI) in Platteville, Colorado. This inspection was an examination of the dry cask storage activities conducted under your site-specific ISFSI license. The NRC inspectors discussed the results of this inspection with Mr. Steven Wahnschaffe, NRC Licensing Manager and Acting NRC Licensed Facility Director, and other members of your staff during an exit meeting conducted on April 17, 2024. The inspection results are documented in the enclosure to this letter.

The inspectors examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

Within these areas, the inspections consisted of selected examination of procedures and representative records, observations of dry cask storage surveillance operations, observations of site meetings, and interviews with personnel. Specifically, the inspection reviewed compliance with the requirements specified in the site-specific ISFSI License SNM-2504, the associated Technical Specifications, the Safety Analysis Report, and the regulations in Title 10 of the Code of Federal Regulations Part 72 and Part 20. Within the scope of the inspection, no violations were identified and a response to this letter is not required.

In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter, its enclosure, and your response if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRCs Website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary information so that it can be made available to the public without redaction. If you have any questions regarding this inspection report, please contact Lee Brookhart at 817-200-1549, or the undersigned at 817-200-1249.

Sincerely, Gregory G. Warnick, Chief Decom., ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Docket No.72-009 License No.SNM-2504

Enclosure:

Inspection Report 07200009/2024001

REGION IV

Docket Nos.: 072-00009

License Nos.: SNM-2504

Report No.: 07200009/2024001

Licensee: U.S. Department of Energy Idaho Operations Office

Facility: Fort Saint Vrain Independent Spent Fuel Storage Installation

Location: Platteville, CO 80651

Inspection Dates: On-site: April 16-17, 2024

Inspectors: L. Brookhart, Senior ISFSI Inspector Decommissioning, ISFSI, and Operating Reactor Branch Division of Reactor Safety and Security, Region IV

J. Freeman, ISFSI Inspector Decommissioning, ISFSI, and Operating Reactor Branch Division of Reactor Safety and Security, Region IV

Accompanied By: T. Bloomer, Director Division of Reactor Safety and Security Region IV

Approved By: G. Warnick, Chief Decommissioning, ISFSI, and Operating Reactor Branch Division of Reactor Safety and Security, Region IV

Attachment: Supplemental Inspection Information

Enclosure EXECUTIVE SUMMARY NRC Inspection Report 07200009/2024001

On April 16-17, 2024, the U.S. Nuclear Regulatory Commission (NRC) performed a routine on-site inspection of the dry fuel storage activities at the Fort St. Vrain (FSV) Independent Spent Fuel Storage Installation (ISFSI) in Platteville, Colorado. The inspection included an evaluation of the current condition of the ISFSI and reviews of several topical areas to evaluate compliance with the applicable NRC regulations and the provisions of the site-specific license. The inspection included reviews of documentation relevant to ISFSI activities and operations that occurred at FSV since the last ISFSI inspection performed in August 2020. The documentation reviewed included quality assurance records, radiological surveys, corrective action reports, and records demonstrating compliance with Technical Specifications and Safety Analysis Report (SAR) requirements. The NRC inspectors did not identify any findings or violations during the inspection.

Away from Reactor ISFSI Inspection Guidance, Inspection Procedure 60858

• The inspectors reviewed the quality assurance audits and surveillances performed by the contractor and the Department of Energy Quality Assurance Department, since the last ISFSI inspection. Issues identified in the quality assurance audits and surveillances were entered into the sites corrective action program for resolution. No findings were identified related to the licensee quality assurance activities. (Section 1.2.a)

• Radiation levels around the ISFSI facility and within the facility were within the expected ranges and areas inside the facility with radiological dose rates were properly posted in accordance with the requirements of 10 Code of Federal Regulations (CFR) Part 20. The ISFSI facility was maintained in good physical condition. Based on documents reviewed and interviews with personnel, areas with observable degradation were repaired or remediated through the sites aging management program. At the time of the inspection there were no observable signs of degradation. (Section 1.2.b)

• Environmental data reviewed from the 2020, 2021, 2022, and 2023 site radiological environmental operating reports determined that radiation levels offsite were nominal and in accordance with the design basis and 10 CFR Part 72.104 requirements. (Section 1.2.c)

• Revisions to the SAR and changes to other major programs since the last inspection were reviewed. There were no changes made to the Radiological Environmental Monitoring Program, the Training Program, the Quality Assurance Program, or Natural Gas and Oil Infrastructure near the site. Revisions 16, 17, and 18 to the SAR were reviewed and changes made were found to meet the requirements of the 10 CFR 72.48 change process.

(Section 1.2.d)

• Selected deficiency reports and corrective action requests were reviewed for the period of August 2020 through April 2024. A wide range of issues had been identified and resolved by the licensee. The issues identified did not have a significant impact on safety and resolution of those issues was appropriate. No adverse trends were identified during the review.

(Section 1.2.e)

• The Fort St. Vrain emergency response plan was being maintained and three revisions to the plan were reviewed by the inspectors. The inspectors determined the changes did not reduce the effectiveness of the plan and did not require NRC approval pursuant to

• 10 CFR 72.44. Drills, exercises, and training were performed in accordance with requirements in the plan. Offsite support agencies were offered an opportunity to participate in the licensees latest biennial exercise. (Section 1.2.f)

• Fort St. Vrain implemented its Aging Management Program, which was required with the-20-year license renewal. The Aging Management Program is documented in the licensees Technical Specifications and SAR. No issues related to maintenance and management of the ISFSI was identified by the inspectors. (Section 1.2.g)

• Site required Technical Specifications associated with the inspection of cooling inlet and outlet screens and the five-year leak tests of spent fuel containers were reviewed for compliance to license conditions. (Section 1.2.h)

Review of 10 CFR 72.48 Evaluations

• The inspectors reviewed a sample of 10 CFR 72.48 screenings and evaluations that had been performed within the inspection period. No findings were identified through the selected sample review. (Section 2.2)

REPORT DETAILS

Summary of Facility Status

The Fort St. Vrain (FSV) Independent Spent Fuel Storage Installation (ISFSI) is a modular vault dry store (MVDS) system developed by Foster Wheeler Energy Corporation. The facility provided storage for the spent fuel from the decommissioned FSV high temperature gas cooled reactor. There were 244 fuel storage containers (FSC) loaded with spent fuel at the FSV ISFSI.

The FSV ISFSI license was transferred from Public Service Company of Colorado to the Department of Energy Idaho Operations Office (DOE-ID) on June 4, 1999. Currently the facility is being maintained by Idaho Environmental Coalition (IEC) as the management and operations contractor for the DOE-ID. At the time of the inspection, the ISFSI was being maintained under site-specific License SNM-2504 Amendment 11 and Safety Analysis Report (SAR) Revision 18.

1. Away From Reactor ISFSI Inspection Guidance (IP 60858)

1.1 Inspection Scope

The inspectors performed a review of the licensees ISFSI activities to verify compliance with requirements of the site-specific License SNM-2504, Amendment 11 and SAR Revision 18. The inspectors reviewed selected procedures, corrective action reports, and records to verify ISFSI operations were compliant with the license Technical Specifications, requirements in the SAR, and NRC rules and regulations.

1.2 Observations and Findings

a. Quality Assurance Audits and Surveillances

Both DOE-ID and the contractor, IEC, had performed numerous Quality Assurance (QA)

audits and QA surveillances of operations at the FSV ISFSI since the last NRC inspection in August 2020. A total of 10 audit reports and 38 surveillance records were sampled for review during the inspection.

The licensees audit and surveillance program encompassed many topical areas and provided in-depth reviews of the licensees ISFSI programs, operations, training, and record keeping. All identified issues were placed into either the licensees corrective action program (CAP) or IECs CAP as deficiency reports (DRs) or Corrective Action Requests (CARs). Each DR or CAR required a formal response from the impacted program department. The inspectors reviewed the problem statements for all DRs and CARs that resulted from the ISFSI audits. The DRs/CARs were evaluated to ensure that the problems being identified were properly categorized based on their safety significance and were properly resolved by the licensee. The inspectors determined corrective actions identified or taken for the issues were appropriate for the significance of the problems being identified. The inspectors did not identify any concerns related to the findings of the sites QA auditing and surveillance program. The audits and surveillances performed met the requirements of 10 CFR 72, Subpart G and the licensees QA program requirements.

b. Radiological Conditions and Tour of the ISFSI

A tour of the FSV ISFSI facility was performed during the inspection. A recent radiological survey of the ISFSI was provided to the inspectors prior to their arrival at the facility. The incoming Facility Director, Licensing Manager, ISFSI Manager, and others accompanied the inspectors during the facility tour. During the tour the inspectors determined that the charge face area of the MVDS system was in good condition. The security tamper seals on the 244 loaded storage positions, each of which contained an FSC, were all intact. No flammable or combustible materials were observed anywhere inside or near the ISFSI facility. Areas within the facility that required postings and/or boundaries were properly roped off and properly posted in accordance with 10 CFR Part 20 requirements.

Areas external to the ISFSI facility were also in good condition. On the outside, the inlet and outlet screens were clear of debris and the ISFSI concrete structure was in good physical condition with no significant observable degradation. The licensee utilized its Aging Management Program to inspect, repair, and assess the ISFSI structures per the license renewal requirements (see Section 1.2.g).

c. Radiological Environmental Monitoring Reports

Annual Radiological Environmental Operating Reports for FSV were reviewed for 2020 through 2023. The sites environmental monitoring program is responsible for measuring the direct radiation impacts of plant operations at 20 optically stimulated luminescent (OSL) dosimeter monitoring stations around the owner-controlled area. All OSL monitoring stations at FSV, including those in close proximity to the ISFSI and at the site boundary, documented the dose equivalent to any real individual located outside of the owner-controlled area were well below the 10 CFR 72.104(a)(2) requirement of less than 25 mrem per year due to the direct radiation influence from the ISFSI. No findings were identified related to the radiological review.

d. Biennial Update Reports and SAR Revisions

The 2021 and 2023 biennial reports were reviewed. The reports provided information related to revisions made during the reporting period to the SAR and certain programs required by the Technical Specifications. The biennial reports included a description of the changes to the SAR for the most recent revisions (16 through 18). The changes to the SAR were editorial corrections, clarifications, changes to contractor and DOE-ID organization, and other minor facility changes that had taken place over the last couple of years. The biennial reports continued by describing that no other changes were made to the following areas: Technical Specifications, Radiological Environmental Monitoring Program, the Training Program, Quality Assurance Program, or Natural Gas and Oil Infrastructure. The inspectors identified no concerns with the changes made by the licensee.

e. Corrective Action Program

The inspectors performed a review of FSVs CAP associated with ISFSI operations.

A list of ISFSI related DRs and CARs issued since the last routine NRC inspection was provided by the licensee during the current inspection. Several DRs and CARs were selected by the inspectors for further review.

The issues discussed in the DRs and CARs, reviewed by the inspectors, covered a broad range of paperwork and maintenance issues that were identified during routine ISFSI storage operations. Based on the types of problems identified, the licensee continued to demonstrate a reasonably low threshold for placing ISFSI and maintenance issues into the CAP. The actions taken for the resolution of the issues were appropriate to the low significance of the issues that were identified. No significant issues or adverse trends were identified during the review of the CAP at FSV.

f. Emergency Planning

Revisions to the licensees Emergency Response Plan since the last NRC inspection were reviewed. The FSV Emergency Response Plan had change three times and was renamed to, PLN-6500, Revision 0. The changes to the FSV Emergency Response Plan resulted from mostly updated formatting requirements, editorial changes, and procedure implementation of a new DOE-ID contractor (IEC) operating the FSV ISFSI. The inspectors reviewed the changes, which were mostly editorial in nature. The inspectors determined the changes did not result in a decrease in the effectiveness of the plan and pursuant to 10 CR 72.44, the changes did not requirement NRC approval.

Required emergency drills/exercises were listed in Section 8.1 of the plan. Required semiannually drills included radiological/health physics drills, medical drills, and fire drills. Biennial exercises were larger drills that tested the adequacy of the implementing procedures, emergency equipment, and communications networks, and ensured the emergency response personnel were familiar with their duties. Offsite response organizations were invited to participate in the biennial exercises. The licensee had successfully conducted the required exercises and drills since the last ISFSI inspection.

A sample of drill packages and the most recent biennial exercise were selected for review. The inspectors determined that the selected drills and the exercise met the objectives of the site Emergency Response Plan. No concerns were identified with the licensees implementation of their emergency response plan.

g. Aging Management Program

As a condition of the FSV license renewal, DOE-ID was required to establish an aging management program to ensure that all ISFSI structures, systems, and components (SSCs) considered important to safety remain functional through the duration of the extended licensing period. The FSV ISFSI license was renewed on July 18, 2011, and included Technical Specification 5.5.5 which required that an Aging Management Program be established as a means for monitoring and mitigating potential aging effects of the modular vault system. The FSV ISFSI Aging Management Program, PLN-6504, Revision 0, specified the specific SSCs that are inspected, which included the fuel storage containers, fuel storage container support stools, standby storage wells, container handling machine raise/lower mechanism, container handling machine fuel storage container grapple, charge face structural steel, cask load/unload port, structural

concrete of the MVDS building, and concrete fill inside the charge face structure.

The inspection and maintenance of these SSCs were implemented through Technical Procedures (TPRs) and Operational Procedures (OPS). Inspection or maintenance periodicity varied from monthly, for some active components, to every 10 years for passive systems. The inspectors reviewed several of the aging management related TPRs/OPSs that were completed during the years since the last inspection. None of the TPR/OPSs reviewed observed any significant deficiencies. No issues related to maintenance and management of the ISFSI were identified by the inspectors.

h. Technical Specification Compliance

Technical Specification 3.1.1.1 required that the cooling inlet and outlet screens be visually inspected every 7 days to verify that no blockage existed. If blockage was observed on the screens, compensatory actions were required with specified time limits.

Procedure records were reviewed for TS compliance for the months of June 2021, December 2021, and July 2022. The licensee had completed the visual inspections in a timely manner and had identified no obstructions during the months selected for review.

Additionally, no obstructions were observed on the inlet and outlet screens during the tour of the facility the week of the inspection.

Technical Specification 3.3.1 required the licensee to conduct a leak test of one fuel storage container from each vault module every 5 years. The latest leak test was performed in 2021. The NRC inspectors reviewed the results of the licensees latest leak test and confirmed that the results were satisfactory and none of the tested locations exceeded the Technical Specification requirements.

1.2 Conclusions

The inspectors reviewed the quality assurance audits and surveillances performed by the contractor and the Department of Energy Quality Assurance Department, since the last ISFSI inspection. Issues identified in the quality assurance audits and surveillances were entered into the sites corrective action program for resolution. No findings were identified related to the licensee quality assurance activities.

Radiation levels around the ISFSI facility and within the facility were within the expected ranges and areas inside the facility with radiological dose rates were properly posted in accordance with the requirements of 10 Code of Federal Regulations (CFR) Part 20.

The ISFSI facility was maintained in good physical condition. Based on documents reviewed and interviews with personnel, areas with observable degradation were repaired or remediated through the sites aging management program. At the time of the inspection there were no observable signs of degradation.

Environmental data reviewed from the 2020, 2021, 2022, and 2023 site radiological environmental operating reports determined that radiation levels offsite were nominal and in accordance with the design basis and 10 CFR Part 72.104 requirements.

Revisions to the SAR and changes to other major programs since the last inspection were reviewed. There were no changes made to the Radiological Environmental Monitoring Program, the Training Program, the Quality Assurance Program, or Natural Gas and Oil Infrastructure near the site. Revisions 16, 17, and 18 to the SAR were reviewed and changes made were found to meet the requirements of the 10 CFR 72.48 change process.

Selected deficiency reports and corrective action requests were reviewed for the period of August 2020 through April 2024. A wide range of issues had been identified and resolved by the licensee. The issues identified did not have a significant impact on safety and resolution of those issues were appropriate. No adverse trends were identified during the review.

The Fort St. Vrain emergency response plan was being maintained and three revisions to the plan were reviewed by the inspectors. The inspectors determined the changes did not reduce the effectiveness of the plan and did not require NRC approval pursuant to 10 CFR 72.44. Drills, exercises, and training were performed in accordance with requirements in the plan. Offsite support agencies were offered an opportunity to participate in the licensees latest biennial exercise.

Fort St. Vrain implemented its Aging Management Program, which was required with the 20-year license renewal. The Aging Management Program is documented in the licensees Technical Specifications and SAR. No issues related to maintenance and management of the ISFSI was identified by the inspectors.

Site required Technical Specifications associated with the inspection of cooling inlet and outlet screens and the five-year leak tests of spent fuel containers were reviewed for compliance to license conditions.

2 Review of 10 CFR 72.48 Evaluations

2.1 Inspection Scope

The licensees 10 CFR 72.48 screenings and evaluations performed since the NRCs last ISFSI inspection were reviewed to determine compliance with regulatory requirements.

2.2 Observations and Findings

The licensee performed several procedure revisions, three SAR revisions, and some equipment or process changes under the 10 CFR 72.48 process since the last inspection. The inspectors reviewed the 10 CFR 72.48 screenings and evaluations for those changes made within the ISFSI program. All screenings and/or evaluations were determined to be adequately performed.

2.3 Conclusions

The inspectors reviewed a sample of the licensees required safety screenings and evaluations that had been performed within the inspection period. No findings were identified during the selected sample review.

3 Exit Meeting Summary

On April 17, 2024, the inspectors presented the final inspection results to Mr. Steven Wahnschaffe, NRC Licensing Manager and Acting NRC Facility Director, DOE-ID, and other members of the licensees staff.

SUPPLEMENTAL INSPECTION INFORMATION PARTIAL LIST OF PERSONS CONTACTED

Licensee Personnel J. Long, ISFSI Program Manager, IEC S. Wahnschaffe, NRC Acting Facility Director and Licensing Manager

INSPECTION PROCEDURES USED

IP 60858 Away from Reactor ISFSI Inspection Guidance

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed None

Attachment LIST OF ACRONYMS USED

ADAMS Agencywide Documents Access and Management System CAP Corrective Action Program CAR Corrective Action Request CFR Code of Federal Regulations DOE-ID Department of Energy Idaho Operations Office DR Deficiency Report FSC Fuel Storage Container FSV Fort Saint Vrain IEC Idaho Environmental Coalition IP Inspection Procedure ISFSI Independent Spent Fuel Storage Installation MVDS Modular Vault Dry Store system NCV non-cited violation NRC U.S. Nuclear Regulatory Commission OPS Operating Procedures OSL optically stimulated luminescent QA Quality Assurance SAR Safety Analysis Report SR Surveillance Requirement SSC structures, systems, and components TPR Technical Procedures

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