ML090140191
| ML090140191 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 01/13/2009 |
| From: | Lipa C A Division of Nuclear Materials Safety III |
| To: | Riemer K R 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.
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 Publicly Available X Non-Publicly Available 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. O'Brien
E. Bonano
M. Learn
S. Bakhsh
Enclosure 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
2 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 eval
uations, 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 275
ûF." 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
Enclosure
3 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.
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 HSM's 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
2 nd 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 Envi
ronmental Operating Report; 4/28/2006 NG-07-0322; 2006 Annual Radiological Envi
ronmental 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