ML19312C489
| ML19312C489 | |
| Person / Time | |
|---|---|
| Site: | 07100017 |
| Issue date: | 11/01/2019 |
| From: | Earl Love NRC/NMSS/DFM/IOB |
| To: | Goodwin C State of RI, Atomic Energy Comm, Nuclear Science Ctr |
| Love E | |
| References | |
| IR 2019201 | |
| Download: ML19312C489 (5) | |
Text
INSPECTOR NOTES COVER SHEET Licensee/Certificate Holder Rhode Island Atomic Energy Commission, Nuclear Science Center (name and address) 16 Reactor Rd Narragansett, RI 02882 Licensee/Certificate Holder Dr. Cameron Goodwin, Director contact and phone number (401) 874-9437 F - (401) 874-9452 caoodwinrinsc. ri.aov Docket No. 071-00017 Inspection Report No. 071-00017/2019-201 Inspection Dates(s) September 19-20, 2019 Inspection Location(s) Narragansett, RI Inspectors Earl Love, Team Leader, Senior Transportation and Storage Safety Inspector Mike Takacs, Security Specialist, NPUF Oversight Branch Summary of Findings and On September 19-20, 2019, the U.S. Nuclear Regulatory Actions Commission (NRC) performed an announced inspection of Rhode Island Atomic Energy Commission, Nuclear Science Center in Narragansett, RI. The purpose of the inspection was to perform a systematic review of RINSC cask quality implementing procedures, used as the basis for their NRC Part 71 QAP approval, to determine whether quality activities are adequately prescribed in operations and maintenance procedures that are to be used in a shipment using the Model No. Battelle Energy Alliance Research Reactor, Type B(U)F, packaging to transport spent fuel elements from the RINSC reactor. Since RINSC is a user-only, the inspection was limited to management controls and operations.
The facility organization consisted of the Facility Director, Assistant Director for Operations, Assistant Director for Radiation and Reactor Safety/Radiation Safety Officer (RSO), Reactor Supervisor, Principle Reactor Operator, Facility Engineer, Reactor Health Physicist (RHP), and administrative support staff. RINSCs Director has responsibility for all the administrative and technical programs of the facility.
From the review of roles, responsibilities, and organizational charts, RINSC's implementation of management and operational controls was assessed to be adequate. Overall, RINSC was assessed to be conducting Part 71 activities in accordance with their NRC-approved Quality Assurance Program. No significant safety concerns were identified.
{'..tJe;;---
Lead Inspector Signature/Date 11/01/2019 Inspector Notes Approval Branch Chief Signature/Date ff$4¥/.6r#?A1JvehaS /0/y p
1
Inspection Background The Rhode Island Atomic Energy Commission is the state agency that serves as the liaison between the State of Rhode Island, and the federal regulating authority. RIAEC has the ultimate responsibility for the Rhode Island Nuclear Science Center (RINSC) Reactor license.
The RIAEC Commissioners provide the general direction for the utilization of the facility.
By application dated January 9, 2019 (ADAMS ML19016A143) Orano Federal Services, the applicant and Certificate of Compliance (CoC) holder, requested a one-time authorization for a shipment using the Model No. Battelle Energy Alliance (BEA) Research Reactor (BRR) package to transport spent fuel elements from the RINSC reactor having a burnup calculated to be more than the amount approved in the transportation packages CoC No. 9341, Revision 7. At the time, the RINSC fuel elements were not authorized contents in CoC (ADAMS ML19038A094).
RINSC identified five spent fuel elements that have a burnup more than the certificate of compliance limit of 52.5 MWd, with a maximum burnup of 52.61 MWd and a minimum cooling time of 589 days.
Based on the statements and representations in the application, and with the conditions listed above, the staff agreed the change does not affect the ability of the package to meet the requirements of 10 CFR Part 71. Subsequently, CoC No. 9341 was amended by letter to authorize shipment of one BRR package containing RINSC fuel elements with a maximum burnup of 52.61 MWd. This authorization expires on May 31, 2020.
Inspection Procedures/Guidance Documents IP-86001, Design, Fabrication, Testing, and Maintenance of Transportation Packagings NUREG/CR-6407, Classification of Transportation Packaging Components According to Importance to Safety NUREG/CR-6314, Quality Assurance Inspections for Shipping and Storage Containers Regulatory Guide 7.10, Establishing Quality Assurance Programs for Packaging Used in the Transport of Radioactive Material Management and Operation Control RINSCs reactor is slated to ship irradiated LEU fuel elements to the Savana River Site (SRS), in Aiken, SC. This evolution will require the use of the BRR cask. The team noted that because RINSC does not ship on a routine basis that Secured Transportation Services, LLC (STS) will be assisting on-site in the preparation for shipments. RINSCs primary responsibility is licensing and cask user registration with support from STS in the performance of loading operations. The team reviewed RINSC kickoff meeting report dated May 22, 2018, summarizing licensing, procedures, and project flow responsibilities. The team noted within the meeting plan STS roles and responsibilities to include: use of BRR Standard operating procedures; assist in development of RINSC procures, and to provide templates for both a quality assurance plan and operational procedures for use of the cask. The team noted that project activities will be carried out in four phases: Pre-shipment, Mobilization, Site Operations, and return of cask to Idaho National Laboratory (INL) a U.S. Department of Energy (DOE) national laboratory operated by BEA.
2
As required by DOE (DOESRAAD-19-131, Spent Nuclear Fuel Acceptance Criteria), the team noted RINSCs completion of a detailed description of the fuel elements and assemblies to be delivered, as well as, the requirement for DOE to authorize to ship. In addition, the team noted the appropriate identification of the cask CoC USA/9341/B(U)F-96, Revision 7.
The team reviewed RINSCs QA Program, 71-0017, Revision 7 that include activities conducted regarding transportation packagings under applicable criteria of 10 CFR Part 71, Subpart H for activities associated with handling, loading and unloading and preparation to a carrier for transport. In addition to the QAP, RINSC has developed a QA Operating Procedures manual (QP-01, dated 04/10/2019) to provide the details for QAP implementation and the generation of quality related documents.
The team noted that RINSCs Facility Director has overall responsibility for implementation and that a QA manager has been assigned to oversee all quality/safety activities and that the appointed individual will not be directly involved in the hands on, day to day execution of activities covered under the QAP. The team noted a RINSCs review and approval of quality documents prior to use/implementation for packaging operations.
The team noted that RINSC has adequately established a quality plan, as well as, implementing procedures for a) packaging and transport (including approval and issuance), b) document control, c) internal receipt, shipping, maintenance and inspections, d) test control, e) control of measuring and test equipment, f) handling, storage and shipping control, g) conditions adverse to quality, h) reporting nonconformances, and i) QA records.
The team reviewed the following RINSC and INL/DOE/BEA documents:
- QAP, Revision 7
- Operating Procedures:
QP-01, Revision 0, dated 05/10/2019, Quality Plan Implementing Procedure QP-02, Revision 0, dated 08/19/2019, Fuel Offload Project Plan
- Quality Assurance Readiness Review Checklist, Revision 0
- Fuel Offload Quality Checklist, Revision 0
- Secured Transportation Services (STS) BRR-P-001, Revision 0, dated 09/04/2019, BRR Package, Trailer and Support Equipment and Receipt Inspection Procedure
- STS-RINSCOPS-001, Revision 0, dated 09/04/2019, Preparation for Fuel Loading
- STS-RINSCOPS-002, Revision 0, dated 09/04/2019, Loading and Closure
- STS-RINSCOPS-003, Revision 0, dated 09/04/2019, Preparation for Transport
- STS-BRR-PSCL-001, dated 09/04/2019, Pre-Shipment Inspection Checklist - BRR Package
- BEA contract No. 00078743, Amendment 2, issued to RINSC, dated 10/18/2019
- BEA contract No. 219906, 219906, issued to STS, dated 05/06/2019
- INL Statement of Work, ID No. SOW-16189, Revision 0, dated 04/22/2019, Rhode Island Nuclear Science Center Spent Fuel Loading and Shipment Support
- NRC User Registration, CoC No. 9341, dated November 14, 2018 Conclusion The team noted that RINSC is the licensee of record for the fuel utilized at the facility and the shipper of record for the spent fuel and that the DOE is the owner of the fuel and is the general licensee for transport or delivery to a carrier for transport and that RINSC shall perform the loading of the SNF into the BRR cask with on-site assistance from DOEs subcontractor STS.
3
Further, the team noted that possession of the fuel at the time of shipment shall be transferred from RINSC licensee to INL at the RINSC site.
Overall, from the review of roles, responsibilities, and organizational charts, RINSCs implementation of management and operational controls was assessed to be adequate. RINSC was assessed to be conducting Part 71 activities in accordance with their NRC-approved Quality Assurance Program. No significant safety concerns were identified.
4