IR 07200020/2024001

Independent Spent Fuel Storage Installation - NRC Inspection Report 07200020/2024001

ML24200A058
Person / Time
Site:	07200020
Issue date:	07/22/2024
From:	Greg Warnick NRC/RGN-IV/DRSS/DIOR
To:	Michael Brown US Dept of Energy, Idaho Cleanup Project
Brookhart L
References
IR 2024001
Download: ML24200A058 (13)

Text

July 22, 2024

SUBJECT:

THREE MILE ISLAND UNIT-2 INDEPENDENT SPENT FUEL STORAGE INSTALLATION - NRC INSPECTION REPORT 07200020/2024-001

Dear Mark C. Brown:

This letter refers to the U.S. Nuclear Regulatory Commissions (NRCs) announced routine inspection conducted on June 25 - 26, 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 Mark Brown, Manager of Idaho Cleanup Project, and other members of your staff during the on-site final exit meeting conducted on June 26, 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 aging management inspection 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-2508 and associated technical specifications, the ISFSI final safety analysis report, and the regulations in Title 10 of the Code of Federal Regulations (CFR) Part 72 and Part 20. No violations were identified and a response to this letter is not required.

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

Sincerely, Gregory G. Warnick, Chief Decom., ISFSI, and Operating Reactor Branch Division of Radiological Safety and Security Docket No.72-020 License No. SNM-2508

Enclosure:

Inspection Report 07200020/2024-001

REGION IV

Docket No. 07200020

License No. SNM-2508

Report No. 07200020/2024-001

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

Location: Idaho Falls, Idaho 83415

Inspection Dates: On-site: June 25-26, 2024

Exit Meeting Date: June 26, 2024

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

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

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

Enclosure EXECUTIVE SUMMARY

NRC Inspection Report 07200020/2024-001

On June 25-26, 2024, the U.S. Nuclear Regulatory Commission (NRC) performed a routine on-site inspection of the dry fuel storage activities of the independent spent fuel storage installation (ISFSI) at the Idaho National Laboratory (INL) outside of Idaho Falls, Idaho. 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 the Three Mile Island Unit-2 (TMI-2) ISFSI facility since the last inspection was performed in June 2021 (ADAMS Accession No. ML21195A379). 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 contractor and the Department of Energy-Idaho Office (DOE-ID) Quality Assurance Department since the last ISFSI inspection. Issues identified in the quality assurance audits and surveillances were entered into the sites corrective action program for resolution. No findings were identified related to the licensees ISFSI quality assurance activities.

(Section 1.2.a)

• Radiation levels around the ISFSI facility were within the expected ranges. The ISFSI facility was maintained in good physical condition. No flammable materials were stored in the ISFSI, all vegetative growth had been controlled, and radiation postings met the requirements 10 Code of Federal Regulations (CFR) Part 20 requirements. (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 Part 72.104. (Section 1.2.c)

• Revisions to the FSAR and changes to other major programs since the last inspection were reviewed. There were no changes made to the radiological environmental monitoring program, the training program, or the quality assurance program. Revisions 12 and 13 to the FSAR were reviewed and changes made were found to meet the requirements of the 10 CFR72.48 change process. (Section 1.2.d)

• Selected deficiency reports and corrective action requests were reviewed for the period of June 2021 through June 2024. A wide range of issues were identified and resolved by the licensee. The issues identified did not impact the safety of the facility and resolutions of those issues were appropriate. No adverse trends were identified during the review.

(Section 1.2.e)

• The TMI-2 ISFSI emergency response plan was being maintained and one revision to the plan was reviewed by the inspectors. The inspectors determined the changes did not reduce the effectiveness of the plan and did not require NRC approval pursuant to 10 CFR 72.44.

Drills, exercises, and training were performed in accordance with requirements in the plan.

Offsite support agencies were offered an opportunity to participate in the licensees latest biennial exercise. (Section 1.2.f)

• The inspectors reviewed a sample of 10 CFR 72.48 screenings and evaluations that had been performed within the inspection period. No findings were identified through the selected sample review. (Section 1.2.g)

REPORT DETAILS

Summary of Facility Status

The Three Mile Island Unit-2 (TMI-2) independent spent fuel storage installation (ISFSI) was loaded with 29 dry shielded canisters (DSCs) in Orano TransNuclear (TN) NUHOMS Horizontal Storage Modules (HSMs). Each DSC contains 12 TMI-2 fuel debris canisters (12T cask system). The ISFSI is maintained under a site-specific NRC Part 72 license. The facility was being maintained by Idaho Environmental Coalition (IEC) as the management and operation contractor for Department of Energy - Idaho Office (DOE-ID). The site currently maintains the ISFSI in accordance with SNM-2508 License Amendment 5 and the final safety analysis report (FSAR) Revision 13.

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-2508 License Amendment 5, and FSAR Revision 13. The inspectors performed an ISFSI pad walkdown, reviewed selected procedures, corrective action reports, and records to verify ISFSI operations were compliant with the licensees certificate of compliance, technical specifications, requirements in the FSAR, and NRC regulations.

1.2 Observations and Findings

a. Quality Assurance Audits

Since the last ISFSI inspection, both DOE-ID and the contractor, IEC, had performed numerous quality assurance (QA) audits and QA surveillances of operations at the TMI-2 ISFSI since the last NRC inspection in June 2021. A total of seven audit reports and 37 surveillance records were sampled for review during the inspection. The licensees audit and surveillance program encompassed many topical areas and provided in-depth reviews of the licensees ISFSI programs, operations, training, and record keeping. The audits covered ISFSI documentation and activities related to ISFSI technical specifications; FSAR requirements; implementation of ISFSI programs; training and qualifications; design control; emergency preparedness; and other ISFSI-related areas.

All identified issues were placed into either the licensees corrective action program (CAP) or IECs CAP as deficiency reports (DRs) or corrective action requests (CARs).

Each DR or CAR required a formal response from the impacted program department.

The inspectors reviewed the problem statements for all DRs and CARs that resulted from the ISFSI audits. The DRs/CARs were evaluated to ensure that the problems being identified were properly categorized based on their safety significance and were properly resolved by the licensee. The inspectors determined corrective actions identified or taken for the issues were appropriate for the significance of the problems being identified. The inspectors did not identify any concerns related to the findings of

the sites QA auditing and surveillance program. The audits and surveillances performed met the requirements of 10 CFR 72, Subpart G and the licensees QA program requirements.

b. Radiological Conditions and Tour of the ISFSI

A tour of the TMI-2 ISFSI was performed during the inspection. A recent radiological survey of the ISFSI was provided to the inspectors prior to arrival at the facility. The ISFSI Manager accompanied the inspectors during the facility tour. During the tour, the inspectors determined that the concrete HSMs and the HSM lids were in good physical condition. No flammable or combustible materials were observed anywhere inside or near the ISFSI and all vegetative growth within the ISFSI fence had been controlled by the licensee. Radiation levels surveyed by the licensee near the edges of the ISFSI remained at background levels. Areas within the ISFSI pad that required postings were properly posted in accordance with 10 CFR Part 20 requirements.

c. Radiological Environmental Monitoring Reports

The TMI-2 ISFSI annual radiological environmental monitoring reports were reviewed for 2021, 2022, and 2023. The sites environmental monitoring program measured the direct radiation impacts of facility operations at 22 dosimetry stations along the outer perimeter fence of the TMI-2 ISFSI. The program includes annually monitoring loose surface radioactive contamination surveys at the vent and purge ports of each DSC and the drain port of each HSM. Additionally, a low-volume air sampler, between the two rows of HSMs, is used to collect air through a particulate filter during a seven-day period each month.

The ISFSI 100-meter security boundary fence locations are the ones used to demonstrate compliance with the 10 CFR 72.104 requirements for radiation dose.

For the three-year period reviewed by the inspectors, the dose measurements at the dosimetry locations remained at consistent levels. The dose results combined with the location of where the nearest individual of the public would be located, demonstrated the maximum dose to the public was well below the 10 CFR 72.104(a)(2) requirement of less than 25 mrem per year. No findings were identified related to the radiological review.

d. Changes to the SNM-2508 License and FSAR

At the time of the last inspection conducted in June 2021, TMI-2 ISFSI utilized SNM-2508 License Amendment 5 and FSAR Revision 11. On September 16, 2019, DOE-ID received a 20-year license renewal for the ISFSI from the NRC. The SNM-2508 ISFSI License Amendment 5 Renewed has an expiration date of midnight on March 19, 2039.

The FSAR was revised twice since the last inspection. Revision 12 updated the FSAR to describe the operations to perform the remote inspection of the DSC and HSM. These changes were part of the aging management program (AMP) established by License Condition 17 and FSAR Section 9.8, titled Aging Management. This program established the processes and procedures to manage the aging of ISFSI components into extended storage periods. Revision 13 updated the FSAR Sections 8 and 9 to recalculate the potential release of radioactive materials from the TMI-2 storage systems during normal,

off-normal, and accident condition using updated software and assumptions. The inspectors identified no concerns with the changes made by the licensee.

e. Corrective Action Program

The inspectors performed a review of TMI-2 ISFSIs CAP associated with ISFSI operations. A list of ISFSI-related DRs and CARs issued since the last routine NRC inspection in June 2021 was provided by the licensee during the current inspection.

Several DRs and CARs were selected by the inspectors for further review.

The conditions discussed in the DRs and CARs reviewed covered a broad range of paperwork and maintenance issues that were identified during routine ISFSI storage operations. Based on the types of problems identified, the licensee continued to demonstrate a reasonably low threshold for placing ISFSI and maintenance issues into the CAP. The actions taken to resolve the issues were appropriate. No significant safety concerns or adverse trends were identified during the review of the CAP at the TMI-2 ISFSI facility.

f. Emergency Planning

A revision to the licensees emergency plan since the last NRC inspection in June 2021 was reviewed. The TMI-2 Emergency Response Plan, PLN-6501, Revision 0 had been issued in November 2022. The changes to the plan were related to only editorial corrections. The inspectors determined the changes were appropriate, did not result in a decrease in the effectiveness of the plan, and pursuant to 10 CR 72.44, the changes did not require NRC approval.

Required emergency drills/exercises were listed in Section 13.5 of the plan. Required annual drills included radiological/health physics drills, medical drills, and fire drills.

Biennial exercises were larger drills that tested the adequacy of the implementing procedures, emergency equipment, and communications networks and ensured the emergency response personnel were familiar with their duties. Offsite response organizations were invited to participate in the biennial exercises. The licensee had successfully conducted the required exercises and drills since the last ISFSI inspection.

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

g. 10 CFR 72.48 Safety Evaluations and 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, two FSAR revisions, equipment changes, 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 contractor and the DOE-ID QA Department since the last ISFSI inspection. Issues identified in the quality assurance audits and surveillances were entered into the sites corrective action program for resolution. No findings were identified related to the licensees ISFSI quality assurance activities.

Radiation levels around the ISFSI facility were within the expected ranges. The ISFSI facility was maintained in good physical condition. No flammable materials were stored in the ISFSI, all vegetative growth had been controlled, and radiation postings met the requirements 10 CFR Part 20 requirements.

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 Part 72.104.

Revisions to the FSAR and changes to other major programs since the last inspection were reviewed. There were no changes made to the radiological environmental monitoring program, the training program, or the quality assurance program. Revisions 12 and 13 to the FSAR were reviewed and changes made were found to meet the requirements of the 10 CFR72.48 change process.

Selected DRs and CARs were reviewed for the period of June 2021 through June 2024.

A wide range of issues were identified and resolved by the licensee. The issues identified did not impact the safety of the facility and all resolutions of those issues were appropriate. No adverse trends were identified during the review.

The TMI-2 ISFSI emergency response plan was being maintained and one revision to the plan was reviewed by the inspectors. The inspectors determined the changes did not reduce the effectiveness of the plan and did not require NRC approval pursuant to 10 CFR 72.44. Drills, exercises, and training were performed in accordance with requirements in the plan. Offsite support agencies were offered an opportunity to participate in the licensees latest biennial exercise.

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

2. Exit Meeting Summary

On June 26, 2024, the inspectors presented the final inspection results of the ISFSI inspection to Mark C. Brown, Manager of Idaho Cleanup Project, and other members of the licensees staff.

SUPPLEMENTAL INSPECTION INFORMATION PARTIAL LIST OF PERSONS CONTACTED

Licensee Personnel Mark C. Brown, Manager of Idaho Cleanup Project, DOE-ID J. Renevitz, NRC Programs Facility Director, DOE-ID S. Wahnschaffe, NRC Programs License Manager, DOE-ID J. Long, Program Manager NRC Licensed Facilities, IEC

INSPECTION PROCEDURES USED

IP 60858 Away from Reactor ISFSI Inspection Guidance

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened None

Closed None

Discussed None

Attachment LIST OF ACRONYMS USED

ADAMS Agencywide Documents Access and Management System AMP Aging Management Program CAP Corrective Action Program CAR Corrective Action Request CFR Code of Federal Regulations DOE-ID Department of Energy - Idaho Operations Office DR Deficiency Report DRSS Division of Radiological Safety and Security DSC dry shielded canisters FSAR Final Safety Analysis Report HSM Horizontal Storage Module IEC Idaho Environmental Coalition INL Idaho National Laboratory IP Inspection Procedure ISFSI Independent Spent Fuel Storage Installation NRC U.S. Nuclear Regulatory Commission QA Quality Assurance TMI-2 Three Mile Island Unit-2 TN Transnuclear

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