ML090140191

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DNMS Input to Integrated Report No. 05000331/2008-005
ML090140191
Person / Time
Site: Duane Arnold  NextEra Energy icon.png
Issue date: 01/13/2009
From: Christine Lipa
Division of Nuclear Materials Safety III
To: Kenneth Riemer
NRC/RGN-III/DRP/B2
References
IR-08-005
Download: ML090140191 (9)


See also: IR 05000331/2008005

Text

January 13, 2009

MEMORANDUM TO: Kenneth Riemer, Chief

Branch 2

Division of Reactor Projects

FROM: Christine Lipa, Chief/RA/

Materials Control, ISFSI, and Decommissioning Branch

Division of Nuclear Materials Safety (DNMS)

SUBJECT: DUANE ARNOLD ENERGY CENTER

DNMS INPUT TO INTEGRATED REPORT NO.

05000331/2008-005

Enclosed is a DNMS report input for the Duane Arnold Energy Center (DAEC) Integrated

Inspection Report No. 05000331/2008-005. This input provides the results of the on-site

inspection conducted on December 17 and 18, 2008, for the operation of an Independent Spent

Fuel Storage Facility Installation (ISFSI) at the DAEC. The inspection consisted of observations

and review of Technical Specification required surveillance activities and data associated with

the ISFSI. In addition, the inspection consisted of document review of ISFSI related corrective

action documents, radiological data, 10 CFR 72.48 screenings and evaluations, and emergency

action level documentation to verify compliance with the conditions of the general license.

The procedures for ISFSI inspections do not include procedure sample requirements.

Please include in report No. 05000331/2008-005 the docket number listed below associated

with dry fuel storage, Docket No. 072-00032.

I have reviewed this input and have determined it is ready for distribution to the licensee and

dissemination to the public.

Docket No. 072-00032

Enclosure:

Inspection Report No. 05000331/2008-005

CONTACT: Jeremy Tapp, DNMS

630-829-9862

DISTRIBUTION:

See next page

See previous concurrence

DOCUMENT NAME: G:\SEC\Work in progress\DAEC 2008 005 DNMS INPUT r1.doc

9 Publicly Available X Non-Publicly Available 9 Sensitive X Non-Sensitive

To receive a copy of this document, indicate in the concurrence box C = Copy without attach/encl; E = Copy with attach/encl N = No copy

OFFICE RIII E RIII E

NAME JTapp;jc* CLipa

DATE 01/08/09 01/13/09

OFFICIAL RECORD COPY

Memorandum to Kenneth Riemer from Christine Lipa dated January 13, 2009

DISTRIBUTION:

R. Orlikowski

T. Ehrig, Site Secretary

R. Baker

N. Shah

K. OBrien

E. Bonano

M. Learn

S. Bakhsh

Cover Letter

No Violations were Identified

TITLE PAGE

Inspector: Jeremy Tapp, Health Physicist, Materials Control, ISFSI, and

Decommissioning Branch, Division of Nuclear Materials Safety (DNMS)

SUMMARY OF FINDINGS

The report covers inspection by regional inspectors of Independent Spent Fuel Storage

Installation activities at Duane Arnold Energy Center.

A. Inspectors-Identified and Self-Revealed Findings

None

B. Licensee-Identified Findings

None

Enclosure

REPORT DETAILS

4 OTHER ACTIVITIES (OA)

4OA5 Other Activities

.1 Operation of an Independent Spent Fuel Storage Installation (ISFSI) at Operating Plants

(60855.1)

a. Inspection Scope

The inspectors conducted a routine inspection of the Duane Arnold Energy Center

(DAEC) ISFSI program to verify compliance with the Certificate of Compliance (CoC),

Technical Specifications, and associated procedures. Specifically, the inspectors

observed and reviewed surveillance activities and historical data, performed a walkdown

of the ISFSI storage pad, and reviewed relevant Corrective Action Program (CAP)

documents, 10 CFR 72.48 screenings and evaluations, environmental and radiological

reports, and emergency action level (EAL) procedures.

The inspectors observed an Operations employee perform the required Technical

Specification surveillance activity to visually verify the horizontal storage module (HSM)

vent screens were clear of debris, and verified this activity was being performed in

accordance with Surveillance Test Procedure (STP) 3.0.0-01, Instrument Checks. The

inspectors observed that Operations was meeting the surveillance requirement but

performed the surveillance from the vehicle by driving next to the ISFSI fence. The

requirement did not specify how to perform the visual inspection of the vent screens, as

long as it could be verified that the vent screens are free of debris. The inspectors

questioned the licensee as to why the ISFSI storage pad was not entered to perform the

surveillance. The licensee wrote CAP 062404, which recommended a procedural

requirement for weekly inspection of the ISFSI storage pad and electrical building. In

addition, the inspectors performed a walkdown of the ISFSI and associated electrical

building to verify no combustibles were in the ISFSI, ISFSI Access Area, or in the

electrical building. The inspectors observed there was no obvious degradation of the

HSMs and the ISFSI and electrical building were generally clean and in good order.

The inspectors reviewed a selection of past Technical Specification surveillance records

since the last inspection in April 2005. The inspectors reviewed data from February

2008, April 2007, May 2006, and December 2005. Data reviewed included both the

Technical Specification required HSM vent screen visual inspection sign offs and HSM

temperature monitoring data. The inspectors reviewed Operating Instruction (OI) 581,

Horizontal Storage Module Temperature Monitoring and noted step (4), which states, in

part, that the following are some investigative Action Steps for HSM temperature

greater than 275F. One of the options is step (4) c. which, in part, states the licensee

can perform Independent verification of HSM Temperature with alternate temperature

measuring equipment The inspectors questioned the licensee on what alternate

measuring equipment and method would be used. The licensee did not have a method

proceduralized and CAP 062407 was written to revise OI 581 to include an alternate

method.

The inspectors reviewed CAPs relevant to ISFSI dating back to the last inspection in

April 2005. No deficiencies were identified in either the actions taken or the timeliness in

the documents reviewed. A list of CAPs reviewed can be found in the attached List of

2 Enclosure

Documents Reviewed section. In addition the inspectors reviewed the 2005, 2006, and

2007 Annual Radiological Environmental Operating Reports to verify 10 CFR 72.104

dose limits were not being exceeded and monitoring equipment is capable of performing

the required measurements. The inspectors also reviewed semi-annual radiation

surveys from June 2005 through October 2008 of the ISFSI to verify there were no

significant changes in dose rates in the area.

The inspectors reviewed 10 CFR 72.48 screening and evaluation documents to verify

any changes made were reviewed appropriately. All changes screened or evaluated

were conservative or administrative in nature. In addition, the inspectors reviewed the

EAL basis document for the ISFSI and associated abnormal operating procedures to

verify actions to be taken for the ISFSI during a design basis scenario were included.

Also, in the unlikely event that a HSM must be removed from service, the procedures to

transfer the dry shielded canister from the ISFSI to the refuel floor to be defueled were

reviewed to verify they could be performed.

b. Findings

No findings of significance were identified.

4OA6 Management Meetings

.2 Interim Exit Meetings

Interim exits were conducted for:

  • Operation of an ISFSI at Operating Plants (60855.1) was discussed with Mr. R.

Anderson, Site Vice President, and other members of licensee management on

December 18, 2008.

3 Enclosure

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

G. Rushworth, Assistant Operations Manager

C. Harberts, Refuel Floor Project Manager

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened None

Closed None

Discussed None

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection. Inclusion on this list does

not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that

selected sections of portions of the documents were evaluated as part of the overall inspection

effort. Inclusion of a document on this list does not imply NRC acceptance of the document or

any part of it, unless this is stated in the body of the inspection report.

4OA5 Other Activities

CAP062404; Performance of NSPEO rounds in the ISFSI; 12/17/2008

CAP062407; Temperature monitoring of HSMs with normal methods unavailable;

12/17/2008CAP060705; NCAQ-Unauthorized combustible material and poor

housekeeping in the ISFSI areas; 10/2/2008

CAP060857; NCAQ-10CFR72.212 evaluation for ISFSI is not clear on inspection

requirement; 10/9/2008

CAP048518; Loss of ISFSI HSM temperature indications; 3/19/2007

CAP060853; CAQ - Several issues identified with ISFSI personnel monitoring and rad

surveys; 10/9/2008

CAP060859; NCAQ- ISFSI pad walkdown identified some material condition issues;

10/9/2008

CAP061486; NCAQ - ISFSI HSM Screens Buckled; 11/3/2008

CAP061909; NCAQ - Fire Brigade truck is 50 short of 2 1/2 hose; 11/21/2008

CAP050999; NRC position on Adoption of revision of dry cask CoC; 7/10/2007

CAP054851; CAQ - NRC position on adoption of CoC Amendments, Part 72 RIS 2007-

26 draft; 1/16/2008

Screening Number 72-176; Modify Daily Check of HSM Temperature; 7/18/2005

Screening Number 72-177; Add Requirements to inspect the site for missile hazards;

8/8/2005

Screening Number 72-178; Remove time requirement of 4 to 12 hrs after shift 2 for the

2nd set of HSM temperature checks; 9/7/2005

Screening Number 72-190; Revision to DFS-801; 7/25/2007

Screening Number 72-191; FSAR Change Request 06-025 for minimum cover of 6 feet

of water above fuel assembly; 10/6/2006

Screening Number 72-197; Reconciliation of Amendment 8 to the CoC; 5/11/2007

Screening Number 72-202; Software Work Request 8223, PPC DCASKZ Software

Application Modification; 9/5/2007

7248SCRN028364; Software Work Request 8359, New Error Checking for Parsing Data

and Error Logging Enhancement; 5/5/2008

7248SCRN032934; Revision to Procedure OI 999, Reactor Building Crane; 10/17/2008

OI 581; Horizontal Storage Module Temperature Monitoring; Revision 1

AOP 901; Earthquake; Revision 17

ACP 118.0; Conduct of the Duane Arnold Energy Center On-Site Dry Spent Fuel

Storage Program; Revision 6

EBD-E; ISFSI Abnormal Events Category; Revision 1

EBD-H; Hazards & Other Conditions Affecting Plant Safety; Revision 9

DFS 304; Loaded Dry Shielded Canister/Transfer Cask from ISFSI to Refueling Floor

Operations; Revision 7

DFS 301; Loaded Dry Shielded Canister/Transfer Cask from Refueling Floor to ISFSI

Operations; Revision 8

DFS 401; Dry Shielded Canister Lid Removal Operations; Revision 5

DFS 402; Transfer Cask/Dry Shielded Canister Fuel Unloading Operations; Revision 2

DFS 203; Dry Shielded Canister Sealing Operations; Revision 12

NG-06-0354; 2005 Annual Radiological Environmental Operating Report; 4/28/2006

NG-07-0322; 2006 Annual Radiological Environmental Operating Report; 4/27/2007

NG-08-0345; 2007 Annual Radioactive Material Release Report and Annual

Radiological Environmental Operating Report; 4/29/2008

Survey #05-1290; ISFSI Pad Semi-annual survey; 6/28/2005

Survey #05-2077; ISFSI Routine; 11/23/2005

Survey #06-958; ISFSI Routine; 6/23/2006

Survey #06-1747; ISFSI Pad Semi Annual Neutron + Beta/Gamma Survey; 11/27/2006

Survey #07-1457; ISFSI Pad Routine - SA Neutron + Beta/Gamma Survey; 6/19/2007

Survey #07-2286; ISFSI Pad Routine Survey - SA Neutron/Beta Gamma; 12/6/2007

Survey #08-885; ISFSI Pad Semi-Annual Routine Survey; 6/28/2008

Survey #08-1369; ISFSI Pad Routine Survey Semi Annual Neutron Beta/Gamma;

10/9/2008

LIST OF ACRONYMS

CAP Corrective Action Program

CoC Certificate of Compliance

CFR Code of Federal Regulations

DAEC Duane Arnold Energy Center

EAL Emergency Action Level

HSM Horizontal Storage Modules

ISFSI Independent Spent Fuel Storage Installation

OI Operational Instruction

STP Surveillance Test Procedure