A
Severity Level IV, cited violation (
VIO) of
10 CFR 72.212, Conditions of general license issued under 72.210, was identified by the inspectors for the licensees repetitive failure to adequately control
transient combustible materials stored in the proximity of loaded dry casks on the
ISFSI pad in accordance with site procedures. On February 3, 2011, while performing a routine walkdown of the
ISFSI enclosed area, the inspectors observed seven storage cradles, multiple storage pallets and storage devices or cribbing located on or near the dry cask storage pad. The cradles, pallets and cribbing, were all constructed of wood products. The nearest items, were wood cradles located approximately 10 to 15 feet from the closest HI-STORM cask loaded with spent fuel. The other wood storage devices were approximately 20 feet from the closest loaded cask and were located both on and off the
ISFSI pad. No apparent work was in progress at the
time of discovery. The inspectors contacted responsible licensee personnel who promptly removed all the
transient combustible material from the
ISFSI exclusion area and initiated PER 318694. The licensee also performed an evaluation of the
transient combustible loading for this material. This was the third occurrence identified by the inspectors of
transient combustibles located in close proximity to HI-Storm casks loaded with spent fuel. The first two occurrences were on May 25, 2010 (see
NCV 07200052/2010002-001,
Transient Combustibles Stored Near Independent Spent Fuel Storage Facility in Excess of Amount Allowed), and on August 17, 2010 (see
NOV 07200052/2010003-001,
Transient Combustibles Stored Near Independent Spent Fuel Storage Facility in Excess of Amount Allowed), in both instances diesel fuel contained in vehicles left parked in close proximity to loaded HI-Storm casks was greater than the maximum allowed. According to NPG-SPP-18.4.7, Control of
Transient Combustibles, the requirements and controls for handling and use of
transient combustibles in proximity of the
BFN ISFSI/Dry Cask Storage Pad were contained within drawings 0-47E201-1 and 0-47E201-2. In particular, drawing 0-47E201-2,
ISFSI Fire Hazards Analysis Compensatory Actions, Item 11 stated that wooden structures facing the
ISFSI were limited to a front face maximum height of 15 feet and a maximum width of 24 feet for a surface area total of 360 square feet, at a distance of 30 feet from the edge of the closest HI-STORM. Furthermore, General Operating Instruction (GOI) 0-GOI-300-1/ATT-12, Outside Operator Round Log, required operators to perform an inspection daily to ensure the
ISFSI Pad and exclusion area were clear of the following: Flammable material such as wood, rags and plastic sheeting. If the
ISFSI pad and exclusion area were not clear of these materials, then report the results to the Unit 3 Supervisor for evaluation of acceptability in accordance with drawing 0-47E201-2. Per 0-GOI-300-1/ATT-12 the
ISFSI Pad exclusion area is defined as within 150 feet of the edges of the
ISFSI Pad in all directions. Based upon discussion with the licensee and a review of work performed in the area, the inspectors determined that the licensee had allowed the wood cradles and cribbing to be left near a loaded HI-STORM cask for approximately one week from on or about January 26 to February 3, 2011. The licensee was performing work in the area to upright and inspect Multi Purpose Containers for the upcoming campaign. However, plant operators had not notified the Unit 3 US of the stored wooden material, and no evaluation had been performed on the acceptability of the
transient combustible material as required by 0-GOI-300-1/ATT-12. Subsequent calculations by the licensee determined that the radiative heat load of the wood items was only about five percent of the allowed
transient combustible loading limit.
