IR 07200017/2020001

Trojan Independent Spent Fuel Storage Installation (ISFSI) - NRC Inspection Report 07200017/2020001

ML20301A887
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	10/27/2020
From:	Greg Warnick Division of Nuclear Materials Safety IV
To:	Jenkins B Portland General Electric Co
References
IR 2020001
Download: ML20301A887 (15)

Text

October 27, 2020

SUBJECT:

TROJAN INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) -

NRC INSPECTION REPORT 07200017/2020001

Dear Mr. Jenkins:

This letter refers to the U.S. Nuclear Regulatory Commissions (NRCs) announced routine inspection conducted on September 30 - October 1, 2020, 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 Mr. Mark Tursa, ISFSI Manager, and other members of your staff during the on-site final exit meeting conducted on October 1, 2020. 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-2509 and associated Technical Specifications, the Trojan ISFSI Final Safety Analysis Report, and the regulations in Title 10 of the Code of Federal Regulations Part 72 and Part 20.

Based on the results of these inspections, the inspectors documented one violation of NRC requirements in this report. The violation was determined to be a Severity Level IV violation of low safety significance under the NRCs traditional enforcement process. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the NRC Enforcement Policy.

If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to: (1) the Regional Administrator, Region IV, and (2) the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001. 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, Digitally signed by Gregory G. Gregory G. Warnick Warnick Date: 2020.10.28 06:12:54 -05'00'

Gregory G. Warnick, Chief Reactor Inspection Branch Division of Nuclear Materials Safety Docket Nos.: 72-017 License Nos.: SNM-2509 Enclosure:

Inspection Report 07200017/2020001

ML20301A887 SUNSI Review ADAMS: Sensitive Non-Publicly Available Keyword:

By: LEB X Yes No X Non-Sensitive X Publicly Available NRC-002 OFFICE DNMS:RxIB DNMS:RxIB DNMS:RxIB NAME LEBrookhart CSmith GGWarnick SIGNATURE LEB WCS GGW DATE 10/27/20 10/27/2020 10/27/2020

U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket No.: 072-00017 License No.: SNM-2509 Report No.: 07200017/2020001 Enterprise Identifier: I-2020-001-098 Licensee: Portland General Electric Company Trojan Independent Spent Fuel Storage Installation Location: Rainier, Oregon 97048 Inspection Dates: On-site: September 30 - October 1, 2020 Exit Meeting Date: October 1, 2020 Inspectors: L. Brookhart, Senior ISFSI Inspector Reactor Inspection Branch Division of Nuclear Materials Safety, Region IV C. Smith, Reactor/ISFSI Inspector Reactor Inspection Branch Division of Nuclear Materials Safety, Region IV Approved By: G. Warnick, Chief Reactor Inspection Branch Division of Nuclear Materials Safety, Region IV Enclosure

EXECUTIVE SUMMARY NRC Inspection Report 07200017/2020001 On September 30 - October 1, 2020, the U.S. Nuclear Regulatory Commission (NRC)

performed a routine on-site inspection of the dry fuel storage activities of the Trojan Independent Spent Fuel Storage Installation (ISFSI) in Rainier, Oregon. 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 Trojan since the last ISFSI inspection performed in December 2017. 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. One Severity Level IV violation of low safety significance was identified for the licensees failure to analyze a credible explosion hazard that could occur at the Prescott Anchorage Area near the ISFSI. The violation was treated as a non-cited violation in accordance with the NRCs Enforcement Policy.

Away from Reactor ISFSI Inspection Guidance, Inspection Procedure 60858

• The licensee conducted quality assurance audits and surveillances of the ISFSI program.

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 licensee quality assurance activities. (Section 1.2.a)

• Radiation levels around the ISFSI facility were within the expected ranges and areas with radiological dose rates were properly posted. 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 maintenance program. At the time of the inspection there were no observable signs of degradation.

(Section 1.2.b)

• Environmental data reviewed from the 2017, 2018, and 2019 site radiological environmental operating reports determined that radiation levels offsite were nominal and in accordance with the design basis and Title 10 of the Code of Federal Regulations (CFR) 72.104.

(Section 1.2.c)

• Since the last NRC ISFSI inspection, Trojan submitted a license amendment request to the NRC and completed a revision 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 May 2017 through August 2020.

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)

• Concrete cask temperature monitoring requirements specified in Technical Specification 5.5.3 were performed daily and vent surveillances were performed weekly as

required. No cask temperature issues were found during the review of selected records.

(Section 1.2.f)

• The Trojan Emergency Response Plan was being maintained. There were no revisions to the plan since the last NRC inspection. 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.g)

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

• The US Army Corps of Engineers installed an anchor buoy designated as the Prescott Anchorage Area on the Columbia River close to the Trojan ISFSI. The NRC opened an Unresolved Item (URI) during the 2015 ISFSI inspection for a potential new explosion hazard from the Prescott Anchorage Area. The inspectors documented one Severity Level IV, non-cited violation for the licensees failure to ensure that the casks were designed and located so that they can continue to perform their safety functions effectively under credible explosion exposure conditions. The inspectors determined that the finding was of low safety significance since the licensee took appropriate corrective actions, determined a potential exposure to explosion from the Prescott Anchorage Area was acceptable, and pursued a license amendment in accordance with 10 CFR 72.48 since the new explosion analysis utilized a new method of evaluation. (Section 1.2.i)

Review of 10 CFR 72.48 Evaluations, Inspection Procedure 60857

• 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 Trojan Independent Spent Fuel Storage Installation (ISFSI) was loaded with 34 storage casks between January 2003 and September 2003 and contains all the spent nuclear fuel generated from the Trojan Nuclear Power Plant. Each BNFL Fuel Solutions TranStor concrete cask contains 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; at the time of this inspection the current revisions are SNM-2509 License Amendment 7 and the FSAR Revision 15.

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-2509, License Amendment 7 and FSAR Revision 15. The inspectors reviewed selected procedures, corrective action reports, and records to verify ISFSI operations were compliant with the license Technical Specifications, requirements in the FSAR, and NRC rules and regulations.

1.2 Observations and Findings a. Quality Assurance Audits The Portland General Electric (PGE) Company had issued two annual audit reports for the Trojan ISFSI since the last inspection conducted in December 2017. 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; procurement control; inspections; Important to Safety operations; and other ISFSI related areas. The inspectors reviewed the 2018 and 2019 Audits of Trojan ISFSI Operations, which were documented in Audit Reports AP 2018-I-032 and AP 2019-I-035.

All identified findings that were adverse to quality were placed into the licensees corrective action program (CAP) as Corrective Action Requests (CARs) and all

recommendations were tracked for evaluation and implementation through the sites Quality Assurance (QA) program. Each CAR required a formal response from the impacted program department. The inspectors reviewed the problem statements for all CARs and recommendation descriptions that resulted from the ISFSI audits. The CARs and recommendations 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 performed met the requirements of 10 CFR Part 72, Subpart G and the licensees QA program requirements.

b. Radiological Conditions and Tour of the ISFSI A tour of the Trojan 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. An ISFSI Specialist accompanied the inspectors during the facility tour. During the tour the inspectors determined that the 34 loaded casks were in good physical condition. No flammable or combustible materials were observed anywhere inside or near the ISFSI pad. Radiation readings were taken near the ISFSI and remained at nominal 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. The ISFSI transfer station, the sites Transfer Cask, and other components that would be used to support cask transfer operations were observed to be in good physical condition with no significant observable degradation. The licensee utilized its ISFSI maintenance program to inspect, repair, and assess the ISFSI structures and components per FSAR requirements (see Section 1.2.h).

c. Radiological Environmental Monitoring Reports Trojan Environmental Dosimetry Reports were reviewed for 2017, 2018, and 2019. The sites environmental monitoring program is responsible for measuring the direct radiation impacts of plant operations at 16 optically stimulated luminescence (OSL) dosimeter monitoring stations. 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 program 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 1 - 6 are the ones used to demonstrate compliance with the 10 CFR 72.104 requirements for radiation dose.

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.

For the three-year period reviewed by inspectors, the dose at OSL locations 1 - 6 were equivalent to background levels and the highest shoreline dose (OSL location 16) was used to calculate 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. The shoreline calculation and the Controlled Access Boundary results demonstrated the maximum dose to an individual of the public was 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-2509 License and FSAR At the time of the last inspection conducted in December 2017, Trojan utilizedSNM-2509 License Amendment 6 and FSAR Revision 14. Since then, Trojan received a 40-year license renewal for the ISFSI from the NRC on August 9, 2019. The SNM-2509 ISFSI License Amendment 7 which included FSAR Revision 15 has an expiration date of midnight on March 31, 2059.

The major changes associated with license and FSAR was the inclusion of Technical Specification 5.5 and FSAR Section 9.7.8, both titled Aging Management Program. This program established the processes and procedures to manage the aging of ISFSI components into extended storage periods. Per the Technical Specification 5.5, the Aging Management Program is required to be implemented on or before 20 years from the date of the first canister loading. Trojans first cask was placed at the ISFSI on January 17, 2003. At the time of the inspection, Trojan was in the process of developing the Aging Management Plan and its implementing procedures that would envelop the FSAR Section 9.7.8 requirements, which was reviewed and approved by the NRC during the license renewal process. The licensee expects to meet the Technical Specification and begin the Aging Management Plans assessments, inspections, and maintenance prior to the January 17, 2023, deadline.

e. Corrective Action Program The inspectors performed a review of Trojans CAP associated with ISFSI operations.

A list of ISFSI related CARs issued since the last routine NRC inspection in December 2017 was provided by the licensee during the current inspection. Several CARs were selected by the inspectors for further review.

The adverse to quality conditions discussed in the CARs reviewed by the inspectors covered a broad range of paperwork and maintenance issues that were identified during routine ISFSI storage operations. 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.

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 or MR system. The actions taken for the resolution of the issues were appropriate to the low safety significance of the issues that were identified. No significant safety concerns or adverse trends were identified during the review of the CAP or MR system at Trojan.

f. Weekly Vent Inspections and Daily Temperature Inspections 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 Trojan ISFSI Procedure (TIP) 17 Concrete Cask Thermal Monitoring Program, Revision 11 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 10, 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 2018, September 2019, and June 2020. The licensee records indicated that the technical specifications had been performed and correctly documented. No abnormal observations were noted.

g. Emergency Planning The sites Emergency Plan was unchanged since the last routine ISFSI inspection in December 2017. The Trojan Emergency Response Plan remained at Revision 10.

Section 7.1.2 of the 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 2019 and the multiple drills packages were selected for additional review. The selected drills met the objectives of site Emergency Response Plan. 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 exercise and offered the opportunity to participate consistent with 10 CFR 72.32(a)(12)(ii). No concerns were identified with the licensees implementation of their emergency response plan.

h. 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 retains 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 logbook. The logbooks contained each years inspection results that documented all defects and irregularities that were found. The defect logbooks also contained detailed pictures of the defects/irregularities that were found. The defects/irregularities that were recorded in the logbooks had before repair and after repair photographs. A select number of defect logbooks were reviewed for the period 2018 and 2019. The inspectors reviewed the annual maintenance records for approximately 10 of the 34 casks, the ISFSI pad, and the transfer station. The inspectors 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 inspectors found that the licensees implementation of their annual maintenance program was performed with significant attention to the detail 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.

i. Columbia River Prescott Anchorage Area In NRC inspection report 2015-001 (ADAMS Accession No. ML15351A487), an Unresolved Item (URI) was documented for a potential new explosion hazard that could occur at the Prescott Anchorage Area (URI 07200017/2015001-001).

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, which is near the Trojan ISFSI. The anchorage is 0.4 miles long and was intended to accommodate one vessel. During the 2015 routine inspection, the NRC inspectors question the potential for the new anchorage point to create new or more severe offsite explosion effects on the ISFSI compared to those discussed in the Trojan FSAR Sections 2.2.3.1 Explosions and Section 8.2.8 Explosions of Chemicals, Flammable Gasses, and Munitions.

The licensee initiated CAR 16-001 to address the explosion hazard concern. The licensee review concluded that certain statements in the Trojan FSAR pertaining to the deterministic evaluation of the design basis explosion event were unable to be confirmed. The corrective actions included performing a quality-related analysis of explosion scenarios from a vessel moored in the Prescott Anchorage Area of the Columbia River, and railcar near the ISFSI, as described in Sections 8.2.8 and 2.2.3.1 of the FSAR. The licensee included a review of railcar explosion scenarios due to the possibility that rail traffic changed since the original analysis was performed.

The new explosion analysis was incomplete during the 2017 routine ISFSI inspection, as documented in NRC inspection report 2017-001 (ADAMS Accession No.

ML18045A073). The licensee completed Calculation No. 2017-09306 Offsite Transportation Explosion Hazard Evaluation in March 2018. The licensee identified that Calculation No. 2017-09306 used a new method of evaluation that was not the FSAR described method for determining peak pressures that would result from an explosion.

Accordingly, the licensee prepared a 10 CFR 72.48 evaluation and concluded that NRC review and approval would be required to make the proposed methodology change.

On March 10, 2020, the licensee submitted License Change Application 72-08 (ADAMS Accession No. ML20083G798) to the NRC for review and approval. The licensees application included the new explosion analysis which used the new method which provided the bases that the ISFSI continues to meet all design criteria.

The inspectors identified that a violation of 10 CFR 72.122 (c) occurred.

Title 10 CFR 72.122 (c) states, in part, that structures, systems, and components important to safety must be designed and located so that they can continue to perform their safety functions effectively under credible fire and explosion exposure conditions.

Contrary to this requirement, from August 2012 to March 2018, the licensee failed to ensure that the ISFSI dry fuel storage casks, which are important to safety, could continue to perform their safety function under credible explosion exposure conditions.

Specifically, the licensee failed to evaluate a new, credible explosion hazard that would result from vessels mooring at the Prescott Anchorage Area on the Columbia River.

This new explosion hazard could adversely affect the FSARs offsite explosion analysis and the design functions of the casks.

This violation was dispositioned per the traditional enforcement process using Section 2.3 of the NRCs Enforcement Policy. The inspectors determined that the finding was of low safety significance because the licensee took appropriate corrective actions and determined, by analysis, that a credible offsite explosion from the Prescott Anchorage would not adversely affect the casks safety functions.

Consistent with the guidance in Section 1.2.6.D of the NRC Enforcement Manual, if a violation does not fit an example in the Enforcement Policy Violation Examples, it should be assigned a severity level: (1) commensurate with its safety significance; and (2) informed by similar violations addressed in the Violation Examples. The violation was evaluated to be similar to a Severity Level IV violation in Enforcement Policy Section 6.5.d.1.

The licensee entered the NRC identified finding into the sites CAP. The licensee restored compliance by performing a new explosion analysis, which concluded that the casks would maintain their safety functions after exposure to explosion conditions. The licensee evaluated the change in accordance with the sites 10 CFR 72.48 process, concluded a license amendment was required, conducted a causal analysis, and initiated corrective actions to preclude reoccurrence. Because the licensee entered the issue into the CAP, the safety significance of the issue was low, and the issue was not repetitive or willful, this Severity Level IV violation was treated as a non-cited violation (NCV), consistent with Section 2.3.2.a of the Enforcement Policy (NCV 07200017/2020-001-01; Failure to Analyze a Credible Explosion Hazard).

The Inspectors determined that based on the licensees corrective actions the URI 07200017/2015-001-01, Use of Prescott Anchorage Bounded by Trojans FSAR, is closed.

1.3 Conclusions The licensee conducted quality assurance audits and surveillances of the ISFSI program. 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 licensee quality assurance activities.

Radiation levels around the ISFSI facility were within the expected ranges and areas with radiological dose rates were properly posted. 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 maintenance program. At the time of the inspection there were no observable signs of degradation.

Environmental data reviewed from the 2017, 2018, and 2019 site radiological environmental operating reports determined that radiation levels offsite were nominal and in accordance with the design basis and Title 10 of the Code of Federal Regulations (CFR) 72.104.

Since the last NRC ISFSI inspection, Trojan had made a single license amendment and revision 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 May 2017 through August 2020. 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.

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.

The Trojan Emergency Response Plan was being maintained. There had been no revisions to the plan since the last NRC inspection. 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.

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 US Army Corps of Engineers installed an anchor buoy designated as the Prescott Anchorage Area on the Columbia River close to the Trojan ISFSI. The inspectors determined that the licensee failed to evaluate a new, credible explosion hazard that would result from vessels mooring at the Prescott Anchorage Area on the Columbia River. This new explosion hazard could adversely affect the FSARs offsite explosion analysis and the design functions of the casks, and was identified as a Severity Level IV, non-cited violation. The NRC determined that the finding was of low safety significance since the licensee took appropriate corrective actions, determined the use of the exposure to explosion effects was acceptable, and pursued a license amendment in accordance with 10 CFR 72.48 since the new explosion analysis utilized a new method of evaluation.

2 Review of 10 CFR 72.48 Evaluations (IP 60857)

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, one FSAR revision, 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 for those changes made within the ISFSI program. One of the screenings led to a 10 CFR 72.48 full evaluation. All screenings and the one evaluation 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 October 1, 2020, the inspectors presented the final inspection results to Mr. Mark Tursa, ISFSI Manager, and other members of the licensees staff.

SUPPLEMENTAL INSPECTION INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel K. Lehman, Admin Assistant J. Vanlooven, RP 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 and Closed 07200017/2020-001-01 NCV Failure to Analyze a Credible Explosion Hazard Closed 2020-001-01 URI Use of Prescott Anchorage Bounded by Trojans FSAR LIST OF ACRONYMS USED ADAMS Agencywide Documents Access and Management System CAB Controlled Area Boundary CAP Corrective Action Program CAR Corrective Action Request CFR Code of Federal Regulations DNMS Division of Nuclear Material Safety FSAR Final Safety Analysis Report IP Inspection Procedure ISFSI Independent Spent Fuel Storage Installation MPC multipurpose canister NCV non-cited violation NRC U.S. Nuclear Regulatory Commission OSL Optically Stimulated Luminescence dosimeter PGE Portland General Electric QA Quality Assurance TIP Trojan ISFSI Procedure URI Unresolved Item Attachment