IR 07200017/2024001
| ML24304A894 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 11/01/2024 |
| From: | Jeffrey Josey NRC/RGN-IV/DRSS/DIOR |
| To: | Felton B Portland General Electric Co |
| Freeman J | |
| References | |
| IR 2024001 | |
| Download: ML24304A894 (13) | |
Text
November 01, 2024
SUBJECT:
TROJAN INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) -
NRC INSPECTION REPORT 07200017/2024001
Dear Benjamin Felton:
This letter refers to the U.S. Nuclear Regulatory Commissions (NRCs) announced routine inspection conducted on October 8 - 9, 2024, 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 Tom Sanders, ISFSI manager, and other members of your staff during the on-site final exit meeting, conducted on October 9, 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 inspection consisted of selected examination of procedures and representative records, observations of ISFSI management activities, and interviews with personnel. Specifically, the inspectors reviewed the dry cask storage operations for compliance with the requirements specified in the site-specific ISFSI license SNM-2509 and associated technical specifications, the ISFSI final safety analysis report (FSAR), 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 817-200-1148.
Sincerely, Jeffrey Josey, Chief Decom., ISFSI, and Operating Reactor Branch Division of Reactor Safety and Security Docket No.: 72-017 License No.: SNM-2509 Enclosure:
Inspection Report: 07200017/2024-001 Signed by Josey, Jeffrey on 11/01/24
ML24304A894 SUNSI Review By: LEB ADAMS:
X Yes No Sensitive X Non-Sensitive Non-Publicly Available X Publicly Available Keyword:
NRC-002 OFFICE SSFSI:DRSS:DIOR SFSI:DRSS:DIOR BC:DRSS:DIOR NAME LBrookhart JFreeman JJosey SIGNATURE
/RA/
/RA/
/RA/
DATE 10/31/24 10/30/24 11/01/24
Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket No.:
072-00017 License No.:
SNM-2509 Report No.:
07200017/2024001 Enterprise Identifier:
I-2024-001-0145 Licensee:
Portland General Electric Company Trojan Independent Spent Fuel Storage Installation Location:
Rainier, Oregon 97048 Inspection Dates:
On-site: October 8 - 9, 2024 Exit Meeting Date:
October 9, 2024 Inspectors:
L. Brookhart, Senior ISFSI Inspector Decom., ISFSI, and Operating Reactor Branch Division of Reactor Safety and Security, Region IV J. Freeman, Reactor/ISFSI Inspector Decom., ISFSI, and Operating Reactor Branch Division of Reactor Safety and Security, Region IV Approved By:
J. Josey, Chief Decom., ISFSI, and Operating Reactor Branch Division of Reactor Safety and Security, Region IV
EXECUTIVE SUMMARY NRC Inspection Report 07200017/2024001 On October 8 - 9, 2024, 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 October 2020 (ADAMS Accession No.
ML20301A887). 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 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 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 in accordance with the requirements 10 Code of Federal Regulations (CFR) Part 20. The ISFSI facility was maintained in good physical condition. No flammable materials were stored in the ISFSI and all vegetative growth had been controlled. Based on observations, 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 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 72.104 requirements. (Section 1.2.c)
Since the last NRC ISFSI inspection, Trojan had completed four revisions to the FSAR. No issues were identified in the review of the changes associated with the FSAR.
(Section 1.2.d)
Selected condition reports were reviewed for the period of October 2020 through September 2024. 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 was one revision to the plan since the last NRC inspection. The inspectors determined the change 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.g)
Annual concrete cask, ISFSI pad, and transfer station inspections were completed in accordance with FSAR requirements. Only minor surface issues were identified and repaired. (Section 1.2.h)
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.i)
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 British Nuclear Fuels, Ltd. (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 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 19.
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 19. The inspectors performed an ISFSI pad walkdown, 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 regulations.
1.2 Observations and Findings a.
Quality Assurance Audits The Portland General Electric (PGE) company had issued six audit reports for the Trojan ISFSI since the last inspection conducted in October 2020. The licensees audit and surveillance program encompassed many topical areas and provided in-depth reviews of the licensees ISFSI programs, operations, security, 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; emergency preparedness, inspections; important to safety operations; and other ISFSI related areas.
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 and ISFSI manager 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. Based on documents reviewed radiation levels near the ISFSI 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 2021, 2022, and 2023. The sites environmental monitoring program is responsible for measuring the direct radiation impacts of plant operations at 16 thermoluminescent dosimeter (TLD) monitoring stations. Eight locations were in close proximity to the ISFSI and were located along the control access area fence (TLD locations 8 - 15). The other 8 locations were further away from the ISFSI but were within the controlled area boundary (TLD 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 TLD monitoring locations to provide the control or background dose (TLD locations 17 and 18).
The ISFSI controlled access boundary monitoring locations 1 - 6 are the instruments 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 TLD locations 1 - 6 were equivalent to background levels and the highest shoreline dose (TLD 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 October 2020, Trojan had recently received a 40-year license renewal for the ISFSI from the NRC. 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 was 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. This required the licensee to begin the aging management plans inspections and assessments prior to January 17, 2023.
Trojan had made several FSAR changes to support aging management plan implementation and general updates for changes that had occurred due to activities on-site. Since the last inspection the FSAR was changed four times and is currently on revision 19. The inspectors reviewed the changes associated with revisions 16-19 and the associated 72.48 reviews performed by the licensee. The changes included updating the FSAR to reflect changes to the licensing basis for potential explosion accident events originating from rail and cargo vessels, which was approved by the NRC in license amendment 7, updating the FSAR to officially implement the new aging management program, changes to the Trojan organizational structure, and general editorial enhancements. The inspectors identified no concerns with the changes made by the licensee.
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 were 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, 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, 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 2020, September 2021, and June 2023. 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 changed from revision 10 to revision 11 since the last routine ISFSI inspection in October 2020. The change was administrative in nature and addressed the restructure of PGE management and communication protocols affected.
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 2021, 2023, and multiple drill 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 As part of the license amendment process for Trojan to receive the 40-year license extension, the licensees maintenance activities, which was previously described in FSAR Section 9.7.6 were moved, changed, and enhanced to become the new aging management program and described in FSAR Section 9.7.8. Trojan officially switched from performing the old maintenance program to the new aging management program activities during the 2022 calendar year to meet the new technical specification that required aging management program implementation by January 17, 2023. The inspectors reviewed documentation associated with both maintenance under the old program as well as assessments and maintenance required by the new aging management program. The licensees programs required inspections of the casks, a sample of canister surfaces, 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. 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 2021, 2022, 2023, and 2024. The inspectors reviewed the annual maintenance records for approximately 8 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 by prepping identified areas, repairing the area with an approved grout, and all canisters were sealed with an approved product. 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.
10 CFR 72.48 Safety Evaluations and Screenings 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, four FSAR revisions, equipment changes associated with aging management activities, 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 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 in accordance with the requirements 10 CFR Part 20. The ISFSI facility was maintained in good physical condition. No flammable materials were stored in the ISFSI and all vegetative growth had been controlled. Based on observations, 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 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 72.104 requirements.
Since the last NRC ISFSI inspection, Trojan had completed four revisions to the FSAR.
No issues were identified in the review of the changes associated with the FSAR.
Selected condition reports were reviewed for the period of October 2020 through September 2024. 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.
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.
The Trojan emergency response plan was being maintained. There was one revision to the plan since the last NRC inspection. The inspectors determined the change 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.
Annual concrete cask, ISFSI pad, and transfer station inspections were completed in accordance with FSAR requirements. Only minor surface issues were identified and repaired.
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.
Exit Meeting Summary On October 9, 2024, the inspectors presented the final inspection results to Mr. Tom Sanders, ISFSI Manager, and other members of the licensees staff.
Attachment SUPPLEMENTAL INSPECTION INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel K. Lehman, Admin Assistant J. Vanlooven, RP and ISFSI Specialist T. Sanders, ISFSI Manager 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 BNFL British Nuclear Fuel Ltd.
CAP corrective action program CAR corrective action request CFR Code of Federal Regulations DRSS Division of Radiological Safety and Security FSAR final safety analysis report IP inspection procedure ISFSI independent spent fuel storage installation MPC multipurpose canister MR maintenance request NRC U.S. Nuclear Regulatory Commission PGE Portland General Electric QA quality assurance TIP Trojan ISFSI procedure TLD thermoluminescent dosimeter