IR 07200011/2021001

Independent Spent Fuel Storage Installation - NRC Inspection Report 07200011/2021-001

ML21077A226
Person / Time
Site:	07200011
Issue date:	03/25/2021
From:	Natasha Greene Division of Nuclear Materials Safety IV
To:	Gacke B Sacramento Municipal Utility District (SMUD)
References
IR 2021001
Download: ML21077A226 (12)

Text

March 25, 2021

SUBJECT:

RANCHO SECO INDEPENDENT SPENT FUEL STORAGE INSTALLATION -

NRC INSPECTION REPORT 07200011/2021-001

Dear Mr. Gacke:

This letter refers to the U.S. Nuclear Regulatory Commissions (NRCs) announced routine inspection conducted on February 23-24, 2021, of the dry cask storage activities associated with your Independent Spent Fuel Storage Installation (ISFSI). The NRC inspectors discussed the results of this inspection with you and other members of your staff during the on-site final exit meeting conducted on February 24, 2021. 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 inspection consisted of selected examination of procedures and representative records, observations of dry cask storage surveillance operations, and interviews with personnel. Specifically, the inspectors reviewed dry cask storage operations and compliance with the requirements specified in the site-specific ISFSI License SNM-2510 and associated technical specifications, the ISFSI Final Safety Analysis Report, and the regulations in Title 10 of the Code of Federal Regulations (CFR) Part 72 and Part 20. 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, Natasha A. Greene, Ph.D., Chief Reactor Inspection Branch Division of Nuclear Materials Safety

Docket No.72-011 License No.: SNM-2510

Enclosure:

Inspection Report 07200011/2021-001

Natasha A.

Greene Digitally signed by Natasha A. Greene Date: 2021.03.25 16:17:41 -05'00'

ML21077A226 X SUNSI Review By: LEB ADAMS:

Yes No Sensitive Non-Sensitive Non-Publicly Available Publicly Available Keyword NRC-002 OFFICE DNMS/RxIB DNMS:RxIB

/ABC/

NAME LEBrookhart NGreene

SIGNATURE

/RA/

/RA/

DATE 03/23/21 03/24/2021

Enclosure

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number:

07200011

License Number:

SNM-2510

Report Number:

07200011/2021-001

Licensee:

Sacramento Municipal Utility District (SMUD)

Facility:

Rancho Seco Nuclear Generating Station and

Independent Spent Fuel Storage Installation

Location:

Herald, California 95638

Inspection Dates:

Onsite: February 23-24, 2021

Exit Meeting Date:

February 24, 2021

Inspectors:

L. Brookhart, Senior ISFSI Inspector

Reactor Inspection Branch

Division of Nuclear Materials Safety, Region IV

Approved By:

Gregory G. Warnick, Chief

Reactor Inspection Branch

Division of Nuclear Materials Safety, RIV

EXECUTIVE SUMMARY

Rancho Seco Independent Spent Fuel Storage Installation

NRC Inspection Report 07200011/2021-001

On February 23-24, 2021, the U.S. Nuclear Regulatory Commission (NRC) performed a routine

on-site inspection of the dry fuel storage activities of the Independent Spent Fuel Storage

Installation (ISFSI) at the Rancho Seco Nuclear Generating Station in Herald, California. 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 Rancho Seco since the last ISFSI inspection was

performed in June 2018 (ADAMS Accession No. ML18241A371). The documentation reviewed

included quality assurance records, radiological surveys, corrective action reports, and records

demonstrating compliance with Technical Specifications and Final Safety Analysis Report

(FSAR) requirements. The NRC inspector 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 licensee 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 licensees ISFSI quality assurance

activities. (Section 1.2.a)

• Radiation levels around the ISFSI facility were within the expected ranges. The ISFSI

facility was maintained in good physical condition. No flammable materials were stored

in the ISFSI, all vegetative growth had been controlled, and radiation postings met the

10 CFR Part 20 requirements. At the time of the inspection there were no observable

signs of degradation. (Section 1.2.b)

• Environmental data reviewed from the 2018 and 2019 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. (Section 1.2.c)

• Since the last NRC ISFSI inspection, Rancho Seco received a license renewal request

from the NRC and completed two revisions to its FSAR. No issues were identified in the

review of the changes associated with the license or FSAR. (Section 1.2.d)

• Selected condition reports were reviewed for the period of June 2018 through

February 2021. A wide range of issues were 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.

(Section 1.2.e)

• The Rancho Seco ISFSI Emergency Response Plan was being maintained and two

revisions to the plan were reviewed by the inspector. The inspector 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)

• 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 1.2.g)

REPORT DETAILS

Summary of Facility Status

The Rancho Seco Independent Spent Fuel Storage Installation (ISFSI) was loaded with 22 dry

shielded canisters (DSCs) based on the Standardized NUHOMS 24P - DSC design. These

DSCs are stored in Orano TransNuclear (TN) Horizontal Storage Modules (HSMs). Twenty-one

of the DSCs contain 493 spent fuel assemblies stored at the ISFSI, and 1 DSC contains

reactor-related Greater Than Class C (GTCC) waste. The ISFSI is maintained under a

site-specific NRC Part 72 license. The canisters containing spent fuel were loaded using

SNM-2510 License Amendment 0 and Final Safety Analysis Report (FSAR), Revision 1 or 2.

The GTCC canister was loaded using SNM-2510 License Amendment 2 and FSAR Revision 3.

The site currently maintains the ISFSI in accordance with SNM-2510 License Amendment 4

Renewed and the FSAR Revision 9.

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-2510, License

Amendment 4 Renewed, and FSAR Revision 9. The inspectors reviewed selected

procedures, corrective action reports, and records to verify ISFSI operations were

compliant with the licensees technical specifications, requirements in the FSAR, and

NRC regulations.

1.2 Observations and Findings

a.

Quality Assurance Audits

Since the last ISFSI inspection, the Rancho Seco Quality Assurance Program issued

two 2019 audit reports and three 2020 audit reports that related to ISFSI activities. 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. The audits covered ISFSI documentation and activities related to ISFSI

Technical Specifications; FSAR requirements; implementation of ISFSI programs;

training and qualifications; design control; emergency preparedness; and other

ISFSI-related areas.

All identified findings or enhancements were placed into the licensees corrective action

program (CAP) as Potential Deviation from Quality reports (PDQs). Each PDQ required

a formal response from the impacted program department. The inspector reviewed the

problem statements for each PDQ that resulted from the five ISFSI audits. The PDQs

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

inspector determined that the corrective actions identified or taken for the issues were

appropriate for the significance of the problems being identified. The inspector did not

identify any concerns related to the findings of the sites quality assurance auditing and

surveillance program. The audits performed met the requirements of 10 CFR Part 72,

Subpart G, and the licensees quality assurance program requirements.

b.

Radiological Conditions and Tour of the ISFSI

A tour of the Rancho Seco ISFSI was performed during the inspection. A recent

radiological survey of the ISFSI was provided to the inspector prior to arrival at the

facility. The ISFSI Manager accompanied the inspector during the facility tour. During

the tour, the inspector determined that the concrete HSMs and the HSM lids were in

good physical condition. No flammable or combustible materials were observed

anywhere inside or near the ISFSI and all vegetative growth within the ISFSI fence had

been controlled by the licensee. Radiation levels surveyed by the licensee near the

edges of the ISFSI remained at background levels. Areas within the ISFSI pad that

required postings were properly posted in accordance with 10 CFR Part 20

requirements.

Areas external to the ISFSI pad were also inspected. A storage building contained the

sites Transfer Cask and other components that would be used to support cask transfer

operations. The equipment was observed to be in good physical condition with no

significant observable degradation.

c.

Radiological Environmental Monitoring Reports

Rancho Seco ISFSI Annual Radiological Environmental Monitoring Reports were

reviewed for 2018 and 2019. The sites environmental monitoring program measured

the direct radiation impacts of plant operations at 10 optically stimulated luminescent

dosimeter (OSLD) monitoring stations which surrounded the ISFSI. Five locations were

in close proximity to the ISFSIs HSMs and were located along the Security Area Fence.

The other five locations were further away from the ISFSI but were within the sites

owner-controlled area. Additionally, the licensee had two control locations which

monitored background levels.

The ISFSI 100-meter security boundary fence locations are the ones used to

demonstrate compliance with the 10 CFR 72.104 requirements for radiation dose. For

the 2-year period reviewed by the inspector, the dose measurements at OSLD locations

along the 100-meter security boundary fence were equivalent to background levels. The

dose results demonstrated the maximum dose to an individual of the public was well

below the 10 CFR 72.104(a)(2) requirement of less than 25 mrem per year. No findings

were identified related to the radiological review.

d. Changes to the SNM-2510 License and FSAR

At the time of the last inspection conducted in June 2018, Rancho Seco utilized

SNM-2510 License Amendment 4 and FSAR Revision 7. Since then, on March 9, 2020,

Rancho Seco received a 40-year license renewal for the ISFSI from the NRC.

The SNM-2510 ISFSI License Amendment 4 Renewed has an expiration date of

midnight on June 30, 2060.

The FSAR was revised twice from Revision 7. The first change, Revision 8, updated the

FSAR based on the changes that were approved by the NRC as part of the license

renewal process. Revision 9 changes were due to the termination of the Rancho Seco

Part 50 license. The revisions contained editorial corrections/changes and updates to

reflect facility changes due to decommissioning activities being terminated.

The major changes associated with license Amendment 4 Renewed and Revisions 8

and 9 of the FSAR were the inclusion of License Condition 21 and FSAR Volume 1,

Section 9.8, titled, Aging Management. This program established the processes and

procedures to manage the aging of ISFSI components into extended storage periods.

Per License Condition 21, the Aging Management Program was required to be

established within 1 year after the issuance of the renewed license (March 9, 2020).

Based on the FSAR Volume 1, Tables 9.8-9 and 9.8-10, the baseline inspections for the

ISFSIs systems, structures, and components were to be completed no later than

2 years after the period of extended operation. Since Rancho Secos license originally

was set to expire on June 30, 2020, the sites first inspections are required to be

completed by June 30, 2022. The licensee expects to meet the License Condition 21

deadline to establish the Aging Management Program prior to March 9, 2021 and

perform the baseline inspections prior to the FSAR deadline of June 30, 2022.

e. Corrective Action Program

The inspectors performed a review of Rancho Secos CAP associated with ISFSI

operations. A list of ISFSI-related PDQs issued since the last routine NRC inspection in

June 2018 was provided by the licensee during the current inspection. Several PDQs

were selected by the inspector for further review.

The conditions discussed in the PDQs reviewed by the inspector 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 to resolve the issues were appropriate. No significant

safety concerns or adverse trends were identified during the review of the CAP at

Rancho Seco.

f.

Emergency Planning

Revisions to the licensees Emergency Plan since the last NRC inspection in June 2018

were reviewed. The Rancho Seco ISFSI Emergency Plan, RSLBD-020, Revision 1, had

been issued in October 2018, and Revision 2 was issued in September 2020. The

changes to the Emergency Plan were related to significant changes due to

decommissioning activities that had been completed onsite and the termination of the

sites Part 50 license. Additional changes included updating maps, editorial corrections,

and removal of activities that were no longer required. The inspectors determined the

changes were appropriate, did not result in a decrease in the effectiveness of the plan,

and pursuant to 10 CR 72.44, the changes did not require NRC approval.

Required emergency drills/exercises were listed in Section 7.3 of the plan. Required

annual 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 inspector determined that the selected drills and the exercise met the

objectives of the sites Emergency Response Plan. No concerns were identified with the

licensees implementation of their Emergency Response Plan.

g. 10 CFR 72.48 Safety Evaluations and Screens

The licensees 10 CFR 72.48 screenings and evaluations performed since the

NRCs last ISFSI inspection were reviewed to determine compliance with regulatory

requirements.

The licensee performed several procedure revisions, two FSAR revisions, and some

process changes through the 10 CFR 72.48 program 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 evaluations were

determined to be adequately performed.

1.3 Conclusions

The inspectors reviewed the quality assurance audits and surveillances performed by

the licensee since the last ISFSI inspection. Issues identified in the quality assurance

audits and surveillances were entered into the sites CAP for resolution. No findings

were identified related to the licensees ISFSI quality assurance activities.

Radiation levels around the ISFSI facility were within the expected ranges. The ISFSI

facility was maintained in good physical condition. No flammable materials were stored

in the ISFSI, all vegetative growth had been controlled, and radiation postings met the

10 CFR Part 20 requirements. At the time of the inspection, there were no observable

signs of degradation.

Environmental data reviewed from the 2018 and 2019 site radiological environmental

operating reports determined that radiation levels offsite were nominal and in

accordance with the design basis and 10 CFR 72.104.

Since the last NRC ISFSI inspection, Rancho Seco received a license renewal from the

NRC and completed two revisions to its FSAR. No issues were identified in the review

of the changes associated with the license or FSAR.

Selected condition reports were reviewed for the period of June 2018 through

February 2021. A wide range of issues were 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 Rancho Seco ISFSI Emergency Response Plan was being maintained and two

revisions to the plan were reviewed by the inspector. The inspector 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.

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.

2.

Exit Meeting Summary

The inspector verified no proprietary information was retained or documented in this

report.

• On February 24, 2021, the inspector presented the final inspection results of the

ISFSI inspection to Mr. Brad Gacke, Manager of Rancho Seco Assets, and other

members of the licensees staff.

Attachment

SUPPLEMENTAL INSPECTION INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

Licensee Personnel

L. Evans, SMUD

B. Gacke, ISFSI Manager

D. Schwarzbart, SMUD

T. Zuck, SMUD

INSPECTION PROCEDURES USED

IP 60858

Away from Reactor ISFSI Inspection Guidance

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Closed

None

Discussed

None

LIST OF ACRONYMS USED

ADAMS

Agencywide Documents Access and Management System

CAP

Corrective Action Program

CFR

Code of Federal Regulations

DNMS

Division of Nuclear Material Safety

DSC

Dry Shielded Canister

FSAR

Final Safety Analysis Report

GTCC

Greater Than Class C

HSM

Horizontal Storage Modules

IP

Inspection Procedure

ISFSI

Independent Spent Fuel Storage Installation

NRC

U.S. Nuclear Regulatory Commission

OSLD

Optically Stimulated Luminescent Dosimeter

PDQ

Potential Deviation from Quality

SMUD

Sacramento Municipal Utility District

TN

Transnuclear