IR 07200017/2017001

Trojan Independent Spent Fuel Storage Installation (ISFSI) Inspection Report 07200017/2017001

ML18045A073
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	02/16/2018
From:	Ray Kellar Division of Nuclear Materials Safety IV
To:	Jenkins B Portland General Electric Co
L. Brookhart
References
IR 2017001
Download: ML18045A073 (18)

Text

UNITED STATES ary 16, 2018

SUBJECT:

TROJAN INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

INSPECTION REPORT 07200017/2017001

Dear Mr. Jenkins:

This letter refers to a routine U.S Nuclear Regulatory Commission (NRC) inspection conducted from December 11-13, 2017, of the dry cask storage activities associated with your Independent Spent Fuel Storage Installation (ISFSI). A preliminary exit was held with your staff on December 13, 2017. After discussion with NRC management and continued review of information provided and gathered during the inspection, a final exit was conducted on January 17, 2018, with Mr. Mark Tursa, ISFSI Manager, and other members of your staff. The enclosed inspection report documents the details of the inspection.

The NRC inspection 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. The inspection reviewed compliance with the requirements specified in your site specific Materials License No. SNM-2509, the associated Technical Specifications, the Trojan ISFSI Final Safety Analysis Report (FSAR), and the regulations in Title 10 of the Code of Federal Regulations (CFR) Part 72 and Part 20.

The inspection reviewed the areas of radiation safety, quality assurance, corrective action program, safety evaluations, cask maintenance, and how you addressed industry issues that affected your ISFSI program. The inspection also reviewed the changes made to your ISFSI program since the last NRC routine ISFSI inspection. The ISFSI operations were found to be in compliance with the applicable NRC regulations and requirements. No violations of NRC regulations were identified.

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 document system (ADAMS), accessible from the NRC Web site 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. Should you have any questions concerning this inspection, please contact the undersigned at (817) 200-1191 or Mr. Lee Brookhart at (817) 200-1549.

Sincerely,

/RA/

Ray L. Kellar, P.E., Chief Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety Docket: 72-17 License: SNM-2509

Enclosure:

Inspection Report 072-00017/2017001 w/attachments:

1. Supplemental Information 2. Loaded Casks at the Trojan ISFSI

REGION IV==

Dockets: 07200017 Licenses: SNM-2509 Report Nos.: 07200017/2017001 Licensee: Portland General Electric Company Facility: Trojan Independent Spent Fuel Storage Installation (ISFSI)

Location: 71760 Columbia River Highway Rainier, OR 97048 Dates: December 11-13, 2017 Inspector: Lee E. Brookhart, Senior Inspector Fuel Cycle and Decommissioning Branch Approved By: Ray L. Kellar, P.E., Chief Fuel Cycle and Decommissioning Branch Division of Nuclear Materials Safety Enclosure

EXECUTIVE SUMMARY Trojan Independent Spent Fuel Storage Installation NRC Inspection Report 07200017/2017001 The U.S. Nuclear Regulatory Commission (NRC) conducted a routine inspection of the licensees programs and activities for safe handling and storage of spent fuel at the Trojan Independent Spent Fuel Storage Installation (ISFSI) on December 11-13, 2017. The inspection reviewed a number of topics to evaluate compliance with the applicable NRC regulations and the provisions of the site-specific license SMN-2509. Trojans unique design utilized a Holtec Multi-Purpose Canister (MPC) and a BNFL Fuel Solutions TranStor concrete over-pack. Thirty-four casks had been loaded and stored on the Trojan ISFSI pad. All spent nuclear fuel was moved to the ISFSI between January 2003 and September 2003. The Part 50 license for the Trojan reactor facility was terminated in 2005. Since then, a majority of the site structures not related to the ISFSI have been dismantled and completely removed from the site. The ISFSI facility was well maintained and dose rates around the perimeter were being monitored.

Perimeter dose rates measured since the fuel was loaded into the ISFSI have continued to drop as the spent fuel decays. A review of the environmental monitoring program demonstrated that radiological exposures to offsite locations and individuals were in compliance with federal regulations. The quality assurance (QA) program and corrective action program were being effectively implemented to capture and correct issues related to the dry cask storage program.

The NRC routine inspection reviewed documentation relevant to ISFSI activities and operations that have occurred at Trojan since the last ISFSI inspection that was performed in December of 2015. In summary, the licensee was conducting ISFSI activities in compliance with regulatory and license requirements.

Away-From-Reactor ISFSI Inspection Guidance (60858)

• The licensee was conducting quality assurance (QA) audits of the ISFSI program. A review of the audit reports determined that the audits were covering a broad range of topics. A number of recommendations were identified in the audits and entered into the ISFSI Activities Database for implementation. (Section 1.2.a)

• Radiation data reviewed from the 2015 and 2016 environmental monitoring reports determined that offsite radiation levels were in compliance with 10 CFR 72.104.

(Section 1.2.b)

• Required records were maintained that described the specific fuel parameters for the spent fuel stored in each of the licensees loaded storage casks. (Section 1.2.c)

• Since the last NRC ISFSI inspection, Trojan had made a single revision to its FSAR in Revision 14. No issues were identified in the review of the changes associated with the revision. (Section 1.2.d)

• Selected condition reports were reviewed for the period December 2015 through December 2017. Licensee resolution of the condition reports were appropriate for the safety significance of the issue. No adverse trends were identified during the review.

(Section 1.2.e)

• Concrete cask temperature monitoring requirements specified in Technical Specification 5.5.3 were performed daily and vent surveillances were performed weekly as required. No temperature issues with the casks were found during the review of selected records. (Section 1.2.f)

• Annual concrete cask, ISFSI pad, and transfer station inspections had been completed in accordance with FSAR requirements. Only minor superficial concrete surface issues were identified and repaired. (Section 1.2.g)

• The inspector verified that the annual site drills and biennial exercises had been performed for the period of 2016 through 2017, in compliance with the sites emergency plan and 10 CFR 72.32 (a)(12) requirements. (Section 1.2.h)

• Internal safety reviews were being conducted as required. A review of the annual reports of the ISFSI Safety Review Committee indicated a strong oversight of ISFSI activities was being implemented by the licensee. (Section 1.2.i)

• The US Army Corps of Engineers installed an anchor buoy designated as the Prescott Anchorage Area on the Columbia River. An Unresolved Item (URI) was opened in the last routine ISFSI inspection to track the licensees review of the use of the anchor to ensure it was bounded by the Trojan FSARs fire hazards and explosions analyses. Since the last inspection the licensee had just received an analysis from a qualified vendor. At the time of the inspection the analysis had not been reviewed nor accepted by the licensee. The NRC plans to review the analysis once the licensee reviews, accepts, and implements the analysis into the license documents during the next routine inspection of Trojans ISFSI.

(Section 1.2.j)

Review of 10 CFR 72.48 Evaluations (60857)

• All required safety screenings had been performed in accordance with the licensees procedures and 10 CFR 72.48 requirements. All screenings reviewed were determined to be adequately evaluated. (Section 2)

Report Details Summary of Facility Status The Trojan Independent Spent Fuel Storage Installation (ISFSI) had been loaded with 34 storage casks between January 2003 and September 2003 containing all the spent nuclear fuel generated from the Trojan Nuclear Power Plant. Each BNFL Fuel Solutions TranStor concrete cask contained one Holtec Multi-Purpose Canister (MPC) of the MPC-24E or MPC-24EF design. The MPC-24E and MPC-24EF are designed to accommodate up to 24 pressurized water reactor fuel assemblies. Trojans ISFSI has a secured protected area which is located adjacent to the area where the Trojan reactor had been originally located. The reactor facility was radiologically remediated to release limits and demolished. The reactor site was released by the NRC from radiological controls under the Part 50 license on May 23, 2005. The ISFSI is maintained under a site-specific NRC Part 72 license. The facility was staffed primarily by personnel who had worked at the Trojan site when it was an operating reactor facility. This staff has continued to maintain the spent fuel in a safe configuration along with the necessary programs and records that confirm compliance with NRC regulations and the site license.

The casks at the Trojan ISFSI were loaded using SNM-2509 License Amendment 3 and Final Safety Analysis Report (FSAR) Revision 2 or 3, but were all currently being maintained under SNM-2509 License Amendment 6 and the FSAR Revision 14 at the time of the inspection.

1 Away-From-Reactor ISFSI Inspection Guidance (60858)

1.1 Inspection Scope An inspection of the status of the loaded casks at Trojan was completed to verify compliance with requirements of its SNM-2509 License, ISFSI FSAR, and federal regulations. The inspection reviewed a broad range of topics including audits conducted under the licensee, condition reports related to the ISFSI, environmental radiological data collected around the ISFSI for the past several years, review of the cask maintenance records, and review of industry issues that affected the sites ISFSI program. A tour of the ISFSI area was performed by the inspector, around the perimeter of the ISFSI pad and near the casks.

1.2 Observations and Findings a. Quality Assurance (QA) Audits and Surveillances The Portland General Electric Company had issued several audit reports for the Trojan ISFSI since the last inspection conducted in December 2015. The audits covered ISFSI documentation and activities related to ISFSI Technical Specifications; FSAR requirements; implementation of ISFSI programs; training and qualifications; design control; procurement control; inspections; Important to Safety operations; and other ISFSI related areas. The inspector reviewed the 2016 and 2017 Audits of Trojan ISFSI Operations, which were documented in Audit Report 2016-I-028 and Audit Report 2014-I-031. In addition, the independent assessment of the 2017 Biennial ISFSI Emergency Exercise was reviewed.

No findings were identified by the Trojan audit teams. All recommendations identified by the QA audits were reviewed and appropriately placed in either the ISFSI Activities

Database or the licensees Corrective Action Program (CAP). The licensees QA audits were found to be quiet extensive and the licensee maintained a low threshold for making audit recommendations. No NRC findings were identified regarding the licensees QA Program audits.

b. Radiological Conditions Related to Stored Casks A tour of the ISFSI pad was performed during the inspection. The tour found the 34 loaded casks to be in good physical condition. No flammable or combustible materials were observed inside the ISFSI protected area fence. A recent radiological survey of the ISFSI pad was provided to the NRC inspector upon arrival on-site.

Offsite and onsite radiological monitoring data from the 2015 and 2016, ISFSI Environmental Monitoring Results were reviewed. The reports were generated by the Trojan Radiological Environmental Monitoring Program (REMP). The program utilized a total of 16 environmental monitoring locations onsite. Trojan had switched from thermoluminescent (TLD) dosimeters to the Optically Stimulated Luminescence (OSL)

dosimeters in the beginning of the 2nd quarter of 2016. Eight locations were in close proximity to the ISFSI and were located along the Control Access Area fence (OSL locations 8 - 15). The other 8 locations were further away from the ISFSI, but were within the Controlled Area Boundary (OSL locations 1 - 7 and 16). The ISFSI Controlled Access Area fence is roughly 50 to 105 feet around the outside of the ISFSI pad. The Controlled Access Boundary is a 200 meter (roughly 656 feet) perimeter around the Trojan ISFSI. The REMP also utilized two OSL monitoring locations to provide the control or background dose (OSL locations 17 and 18).

The ISFSI Controlled Access Boundary monitoring locations are the ones used to demonstrate compliance with the 10 CFR 72.104 requirements for radiation dose.

Locations 1-6 represent OSL locations at or near the licensees designated controlled area boundary. The highest reading from OLSs 1-6 were used to calculate the maximum dose rate from the ISFSI pad. Monitoring locations 7 and 16 were much closer to the ISFSI pad on the shoreline side of the site at distances of 100 and 30 meters, respectively. The higher of those two measurements was used to calculate the annual recreational shoreline dose attributable to the ISFSI.

The licensee calculated that the maximum dose that could have been received as a result of the ISFSI operations for the year 2015 was an occupational dose of 5.9 milliRoentgen (mrem) based on TLD monitoring location 6 and a recreational dose of 1.5 mrem based on TLD monitoring location 16. The following year, 2016, the calculated doses were based on the more accurate OSL monitoring data, which resulted in a calculated occupational dose of 0.2 mrem for OSL monitoring location 6 and a recreational dose of 0.6 mrem for OSL monitoring location 16. The occupational dose was calculated using an occupancy factor based on 2,080 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> worked on site per year. The shoreline dose was calculated using a recreational factor based on 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of time spent at the shoreline or boating near the site per year. Both of the calculated values were below the 10 CFR 72.104 dose requirement which limited the dose to less than 25 mrem per year.

c. Cask Records of Fuel Contents Permanent records describing the spent fuel stored in Trojans ISFSI are required by 10 CFR 72.212(b)(12). A review of the Trojan ISFSI records was performed to determine if an adequate description of the spent fuel loaded in the casks was documented as a permanent and retrievable record. The fuel assembly contents of each of the loaded canisters used at Trojan were documented in an online database and in binders titled, Spent Nuclear Fuel Verification Plan. Records for fuel burn up in megawatt days per metric ton uranium (MWD/MTU), original U-235 enrichment percentage, and discharge date were found in Section 3 of the binder, Trojan Nuclear Plant Fuel SNM Inventory. The heat load calculation data was stored in another file titled Trojan ISFSI MPC Heat Load Calculation. Spreadsheets attached to that document were reviewed and was verified to contain each fuel assemblies decay heat in watts. No issues, regarding record retention, were identified by the NRC inspector.

d. Changes to the SNM-2509 License and FSAR At the time of the last inspection conducted in December 2015, Trojan was utilizing SNM-2509 License Amendment 6 and FSAR Revision 13. Since then Trojan had made a single revision to the FSAR in Revision 14, dated February 1, 2017.

The major changes associated with Revision 14 of the FSAR included updating a number of sections in the FSAR due to a revised postulated transfer cask drop evaluation involving a partially loaded MPC. This revised analysis was performed to address a vendor bulletin, which identified the partially loaded canister required additional analysis to ensure it was adequately bounded by a fully loaded canister drop analysis. The new drop analysis demonstrated that the resulting drop g-loads of a partially loaded canister did not exceed (or approach) any limit specified in the design basis documents for a fully loaded canister.

Additional changes in Revision 14 consisted of general editorial updates and adding additional information associated with Trojans ISFSI decommissioning plan. No issues were identified relating to review of the FSAR changes.

e. Corrective Action Program A list of condition reports issued since the last NRC inspection was provided to the inspector by the licensee for the ISFSI activities. The inspector found that the issues were processed in accordance with Trojan ISFSI Procedure (TIP) 50 Corrective Action Program, Revision 3. When an adverse to quality issue was identified, the licensee would document the issue as a Corrective Action Request (CAR) and assign a CAR tracking number. When issues were identified that did not meet the definition of adverse to quality, the licensee would capture the issue and resolution of the condition through the sites Maintenance Request (MR) system. All issues identified were given a MR number and resolutions were tracked in the MR systems database.

From the short list of condition reports and longer list of maintenance requests relating to the ISFSI and site operations, a total of five CARs and approximately 20 MRs were selected by the inspector for additional review. The CARs and MRs were related to a variety of issues. The CARs reviewed were well documented and were properly categorized based on the safety significance of the issue. The corrective actions taken were appropriate for the situations. Based on the level of detail of the CARs and MRs,

the licensee demonstrated a high attention to detail in regard to the maintenance and operation of its ISFSI program. No NRC safety concerns were identified related to the CARs or MRs reviewed.

f. Weekly Vent Inspections and Daily Temperature Inspections per TS 5.5.3 Trojans License SNM-2509 Technical Specification 5.5.3 required that the air outlet temperature and the ambient air temperature for each cask be measured daily. In addition to the temperature checks, all air inlet vents for each concrete cask was required to be inspected weekly to verify each vent was free of blockage. To perform these actions the licensee utilized Procedure TIP 17 Concrete Cask Thermal Monitoring System, Revision 7 for recording the concrete cask temperatures obtained from a digital readout.

The change in temperature between the outlet vents and the ambient temperature was recorded and reviewed to ensure the difference was below 180 degrees F. Licensee Procedure TIP 12 Monitoring of the Concrete Cask System, Revision 9, incorporated the technical specification requirement for weekly visual inspection of all concrete cask air vents for blockage. Documentation of both required surveillances were reviewed for the months of December 2015, September 2016, and June 2017. The licensee records indicated that the technical specifications had been performed and correctly documented.

No abnormal observations were noted during the reviewed time frames.

g. Concrete Casks, ISFSI pad, and Transfer Station Annual Visual Inspection Trojan FSAR Section 9.7.6 required periodic inspection of the concrete casks, ISFSI pad, and transfer station to ensure structural integrity. An annual inspection program was implemented by the licensee using Procedure TIP 09, Structural Inspection Program, Revision 7. Procedure TIP 09 discussed the annual visual inspection of the casks, the storage pad surface, the ISFSI pad surface, the transfer pad surface, and the transfer station. All steel, concrete surfaces, including cask vertical surfaces, and the inlet/outlet screens were visually inspected for defects and irregularities. The definition section of the procedure provided clear definitions for defects and irregularities. For the concrete casks, a defect of the concrete surface was described as scabbing, spalling or cracking larger than approximately 1/2 inch in diameter or width with a depth greater than 1/4 inch. For the pad, a defect was defined as visible signs of settling, movement, or holes/large cracks greater than 1/2 inch across and extending to the rebar.

The licensee had kept very detailed documentation on the annual visual inspections performed on the casks, ISFSI pad, and transfer station. Each cask, the ISFSI pad, and the transfer station had its own defect log book. The log books contained each years inspection results that documented all defects and irregularities that were found. The defect log books also contained detailed pictures of the defects/irregularities that were found. The defects/irregularities that were recorded in the log books had a before repair and after repair photograph. A select number of defect log books were reviewed for the period 2016 and 2017. The NRC inspector reviewed the annual maintenance records for approximately 12 of the 34 casks, the ISFSI pad, and the transfer station. The inspector verified that no significant issues were identified by the licensee during those inspections. All small defects/irregularities such as small holes and pitting were noted for repair. The discrepancies identified by the licensee were repaired with an approved silicone sealant. The inspector found that the licensees implementation of their annual maintenance program was performed with significant attention to the details associated

with the repair and documentation of all defects which ensured the casks, ISFSI pad, and transfer station remained in excellent condition. No issues were identified related to the licensees annual maintenance program.

h. Emergency Plan The licensee had not made a change to the sites Emergency Plan since the last routine ISFSI inspection in December 2015. The Trojan Emergency Plan had remained at Revision 10.

Section 7.1.2 of the emergency plan required a fire, a medical, and a radiological/health physics drill to be performed on an annual basis. In addition to the three drills, a site exercise was required biennially. The licensee had successfully conducted all the required drills and exercises since the last ISFSI inspection. The biennial exercise package for 2017 and the multiple drills packages were selected for additional review.

The selected drills met the objectives of site Emergency Plan Step 7.1. The drill and exercise packages included a description of the drill that was conducted, a timeline, a synopsis, and a drill/exercise critique. All recommendations identified in the critiques were placed into the licensees ISFSI Activities Database for tracking purposes. Offsite support agencies, including the Columbia River Fire and Rescue, the Oregon Department of Energy, the United States Coast Guard, and the Columbia County Emergency Management, were notified of the exercises and offered the opportunity to participate consistent with 10 CFR 72.32 (a)(12)(ii).

i. Safety Review Committee Activities of the ISFSI Safety Review Committee (ISRC) were reviewed, including the annual reports for 2016 and 2017. The ISRC Charter is established in Procedure TIP 02, ISFSI Safety Review Committee Charter, Revision 2. The charter defined the purpose and responsibilities of the ISRC, membership requirements, training and qualification requirements for members, topical areas to be reviewed by the ISRC, and meeting/quorum requirements. The assigned members to the ISRC were documented in writing and approved by the ISRC Chairman and the Corporate Executive Responsible for Trojan on TIP 02, Attachment 1, ISRC Membership Training and Qualification Requirements. The ISRC meetings discussed numerous topics, including staffing level and upcoming retirements, license renewal, site improvement projects, NRC inspections, ISFSI security, emergency planning, readiness for severe natural phenomena events, financial assurance, recently conducted QA audits, and implementation of the site QA program. Good discussions were documented in the annual meeting reports indicating the ISRC members were taking a broad look at site activities.

j. Columbia River Prescott Anchorage Area In the last routine ISFSI inspection (ADAMS Accession No. ML15351A487), a URI was documented relating to the licensees review to ensure that the use of the Prescott Anchorage Area still meets the analyses of the Trojans FSAR for explosions and fire hazards (URI 72-17/1501-01).

In August 2012, the US Army Corps of Engineers installed an anchor buoy for the newly designated Prescott Anchorage Area on the Columbia River. The anchor buoy is

located along the Columbia River between mile markers 72.1 and 72.5. The anchorage is 0.4 miles long and was intended to accommodate one vessel. During the past routine inspection, the NRC inspector was unable to determine if the supporting analyses for Trojan FSAR Sections 2.2.3.1 Explosions and Section 8.2.8 Explosions of Chemicals, Flammable Gasses, and Munitions remained bounding due to the large ships utilizing the installed buoy.

Since the last inspection, the licensee initiated CAR 16-001 to address the NRCs URI.

The corrective actions from the CAR included contracting a qualified vendor to perform a quality-related analysis of the probability and consequences of the river and railcar explosion scenarios on the ISFSI as described in Sections 8.2.8 and 2.2.3.1 of the FSAR. The licensee included a review of railcar scenarios since rail traffic had possibly changed since the original analysis was performed. The results of this analysis was to be incorporated into Trojan licensing documents as appropriate.

At the time of the NRC inspection, Trojan had just received the vendors analysis. The analysis had not been formally reviewed nor accepted by the licensee at the time of the inspection. The NRC plans to review the analysis once the licensee reviews, accepts, and implements the analysis into the license documents during the next routine inspection of Trojans ISFSI.

1.3 Conclusions The licensee was conducting QA audits of the ISFSI program. A review of the audit reports determined that the audits were covering a broad range of topics. A number of recommendations were identified in the audits and entered into the ISFSI Activities Database for implementation.

Radiation data reviewed from the 2015 and 2016 environmental monitoring reports determined that offsite radiation dose levels were in compliance with 10 CFR 72.104.

Required records were maintained that described the specific fuel parameters for the spent fuel stored in each of the licensees loaded storage casks.

Since the last NRC ISFSI inspection, Trojan had made a single revision to its FSAR in Revision 14. No issues were identified in the review of the changes associated with the revision.

Selected condition reports were reviewed for the period December 2015 through December 2017. Licensee resolutions of the condition reports were appropriate for the safety significance of the issue. No adverse trends were identified during the review.

Concrete cask temperature monitoring requirements specified in Technical Specification 5.5.3 were performed daily and vent surveillances were performed weekly as required. No temperature issues with the casks were found during the review of selected records.

Annual concrete cask, ISFSI pad, and transfer station inspections had been completed in accordance with FSAR requirements. Only minor superficial concrete surface issues were identified and repaired.

The inspector verified that the annual site drills and biennial exercises had been performed for the period of 2016 through 2017, in compliance with the sites emergency plan and 10 CFR 72.32 (a)(12) requirements.

Internal safety reviews were being conducted as required. A review of the annual reports of the ISFSI Safety Review Committee indicated a strong oversight of ISFSI activities was being implemented by the licensee.

The US Army Corps of Engineers installed an anchor buoy designated as the Prescott Anchorage Area on the Columbia River. A URI was opened in the last routine ISFSI inspection to track the licensees review of the use of the anchor to ensure it was bounded by the Trojan FSARs fire hazards and explosions analyses. Since the last inspection the licensee had just received an analysis from a qualified vendor. At the time of the inspection the analysis had not been reviewed nor accepted by the licensee.

The NRC plans to review the analysis once the licensee reviews, accepts, and implements the analysis into the license documents during the next routine inspection of Trojans ISFSI.

2 Review of 10 CFR 72.48 Evaluations (60857)

2.1 Inspection Scope The licensees 10 CFR 72.48 screenings and evaluations since the December 2015 routine ISFSI inspection were reviewed to determine compliance with regulatory requirements.

2.2 Observations and Findings A list of modifications to the ISFSI program including procedure revisions was provided by the licensee. Seven 10 CFR 72.48 screenings were selected for further review.

No full 72.48 safety evaluations were completed since the last NRC inspection. The licensee utilized Procedure TIP 05 10 CFR 72.48 and Other Regulatory Evaluations, Revision 7 to perform the 10 CFR 72.48 safety screenings and evaluations. The Five 72.48 screenings were reviews performed to change some ISFSI operations procedures. Two 72.48 screens were completed to update the sites FSAR. No other modifications to the ISFSI equipment, components, or the facility had been performed since the last inspection. No issues were identified in the review of the 72.48 screens.

2.3 Conclusions All required safety screenings had been performed in accordance with the licensees procedures and 10 CFR 72.48 requirements. All screenings reviewed were determined to be adequately evaluated.

3 Exit Meeting The inspector reviewed the scope and findings of the inspection during a telephonic exit conducted with Mr. Mark Tursa, ISFSI Manager, and other members of the Trojan ISFSI staff on January 17, 2017.

SUPPLEMENTAL INSPECTION INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel B. Eder, ISFSI Specialist M. Kramberg, ISFSI Specialist K. Lehman, Admin Assistant J. Vanlooven, Radiation Protection and ISFSI Specialist M. Tursa, ISFSI Manager INSPECTION PROCEDURES USED IP 60858 Away-From-Reactor ISFSI Inspection Guidance IP 60857 Review of 10 CFR 72.48 Evaluations LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Discussed 72-17/1501-01 URI Use of Prescott Anchorage Bounded by Trojans FSAR Closed None Attachment 1

LIST OF ACRONYMS ADAMS Agencywide Documents Access and Management System CAP Corrective Action Program CAR Corrective Action Request CFR Code of Federal Regulations FSAR Final Safety Analysis Report ISFSI Independent Spent Fuel Storage Installation kW kilo-watt MPC multipurpose canister MWD/MTU megawatt days/metric ton uranium NRC U.S. Nuclear Regulatory Commission OSL Optically Stimulated Luminescence dosimeter QA Quality Assurance REMP Radiological Environmental Monitoring Program TLD thermoluminescent dosimeter TIP Trojan ISFSI Procedure U-235 Uranium 235 URI Unresolved Item

LOADED CASKS AT THE TROJAN ISFSI LOADING HOLTEC ISFSI CONCRETE DATE HEAT LOAD BURNUP MAXIMUM FUEL PERSON-REM ORDER MPC No. LOCATION CASK No. ON PAD (kW) MWd/MTU (max) ENRICHMENT % DOSE

28 E33 PCC-03 January 17, 2003 6.247 39,110 3.56 0.236

26 E32 PCC-04 January 26, 2003 6.872 38,877 3.56 0.238

35 E11 PCC-09 February 5, 2003 17.432 41,889 3.46 1.145

11 E12 PCC-10 February 12, 2003 15.896 41,278 3.20 0.950

18 E13 PCC-05 February 16, 2003 15.426 39,966 3.45 0.905

22 E14 PCC-06 February 22, 2003 14.692 39,040 3.30 0.660

36 E15 PCC-07 March 5, 2003 13.898 40,032 3.20 0.778

37 E16 PCC-08 March 13, 2003 12.187 40,632 3.20 0.446

38 E21 PCC-11 March 19, 2003 15.118 40,917 3.30 0.523

24 E22 PCC-12 March 26, 2003 17.009 36,364 3.40 0.472

30 E23 PCC-13 April2, 2003 16.108 38,860 3.40 0.452

31 E24 PCC-14 April 7, 2003 15.611 38,769 3.40 0.402

32 E25 PCC-15 April 14, 2003 13.920 39,345 3.39 0.341

34 E26 PCC-16 April 20, 2003 11.648 35,019 3.11 0.305

39 E31 PCC-02 April 26, 2003 14.365 38,718 3.30 0.630 Attachment 2

LOADING HOLTEC ISFSI CONCRETE DATE HEAT LOAD BURNUP MAXIMUM FUEL PERSON-REM ORDER MPC No. LOCATION CASK No. ON PAD (kW) MWd/MTU (max) ENRICHMENT % DOSE

09 E34 PCC-17 May 2, 2003 15.362 37,698 3.40 0.461

29 E35 PCC-18 May 9, 2003 13.878 38,269 3.46 0.881

15 E36 PCC-19 May 14, 2003 10.973 37,681 3.10 0.437

08 W11 PCC-20 May 18, 2003 13.336 40,730 3.20 0.461

12 W14 PCC-21 May 24, 2003 14.55 37,009 3.40 0.460

16 W15 PCC-22 May 28, 2003 13.969 38,116 3.42 0.443

17 W16 PCC-23 June 3, 2003 10.931 33,830 3.10 0.272

07 W21 PCC-24 June 10, 2003 12.889 38,932 3.11 0.442

27 W22 PCC-25 June 15, 2009 13.228 40,244 3.45 0.514

13 W24 PCC-26 June 20, 2003 11.870 37,850 3.42 0.240

19 W25 PCC-27 June 26, 2003 10.071 37,461 3.56 0.182

20 W26 PCC-28 July 1, 2003 10.855 38,215 3.20 0.348

21 W31 PCC-29 July 6, 2003 10.497 35,363 3.10 0.297

23 W32 PCC-30 July 11, 2003 10.483 37,729 3.09 0.249

25 W33 PCC-31 July 17, 2003 9.652 33,187 3.10 0.207

40 W34 PCC-32 July 22, 2003 8.911 30,150 2.61 0.195

41 W35 PCC-33 July 28, 2003 8.719 33,732 3.10 0.275

LOADING HOLTEC ISFSI CONCRETE DATE HEAT LOAD BURNUP MAXIMUM FUEL PERSON-REM ORDER MPC No. LOCATION CASK No. ON PAD (kW) MWd/MTU (max) ENRICHMENT % DOSE

42 W36 PCC-01 July 31, 2003 8.467 29,595 2.61 0.250

33 W23 PCC-34 September 3, 2003 12.183 37,153 3.42 0.626 NOTES: Heat load (kW) is the sum of the heat load values for all spent fuel assemblies in the cask Burn-up is the value for the spent fuel assembly with the highest individual discharge burn-up Fuel enrichment is the spent fuel assembly with the highest individual initial enrichment per cent of U-235 All casks are currently maintained under SNM-2509, License Amendment 6 and the Final Safety Analysis Report, Revision 14.

ML18045A073 SUNSI Review ADAMS: Sensitive Non-Publicly Available Keyword By: LEB Yes No Non-Sensitive Publicly Available NRC-002 OFFICE RIV/DNMS/FCDB RIV/DNMS/FCDB/BC NAME LBrookhart RKellar SIGNATURE /RA/ /RA/

DATE 2/15/18 2/16/18