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Idaho Cleanup Project ICP TSR Violations and Enhanced Oversight and Recovery for Spent Fuel Operations

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Idaho Cleanup Project ICP TSR Violations and Enhanced Oversight and Recovery for Spent Fuel Operations

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    1. Idaho Cleanup Project (ICP) TSR Violations and Enhanced Oversight and Recovery for Spent Fuel Operations Brad Davis DOE-ICP Facility and Materials Disposition Project (FMDP) - Facility Operations Idaho Nuclear Technology and Engineering Center (INTEC) davisbj@id.doe.gov

    2. 2 ICP – TSR Violations and Enhanced Oversight and Recovery for Spent Fuel Operations One of the primary missions of the INTEC facility is the safe interim storage of spent nuclear fuel within four facilities

    3. 3 ICP – TSR Violations and Enhanced Oversight and Recovery for Spent Fuel Operations CPP-603 Irradiated Fuel Storage Facility (IFSF) is a dry storage facility containing nuclear fuels unsuitable for long term wet storage. 660 storage positions in the fuel storage area.

    4. 4 ICP – TSR Violations and Enhanced Oversight and Recovery for Spent Fuel Operations CPP-603 Irradiated Fuel Storage Facility (IFSF)

    5. 5 ICP – TSR Violations and Enhanced Oversight and Recovery for Spent Fuel Operations CPP-666 Fluorinel Dissolution Process and Fuel Storage (FAST) - only active under-water fuel storage facility at INTEC. Various spent fuel types are stored in over 1700 storage positions within the six stainless steel lined fuel storage pools. 12/31/23- all fuel removed.

    6. 6 ICP – TSR Violations and Enhanced Oversight and Recovery for Spent Fuel Operations CPP-666 Fluorinel Dissolution Process and Fuel Storage (FAST)

    7. 7 ICP – TSR Violations and Enhanced Oversight and Recovery for Spent Fuel Operations CPP-749 Underground Dry Fuel Storage Area consists of 218 underground silos which store fuel deemed unsuitable for underwater storage. These vaults are constructed of concrete and steel and include liquid intrusion or gas buildup monitoring systems.

    8. 8 ICP – TSR Violations and Enhanced Oversight and Recovery for Spent Fuel Operations CPP-749 Underground Dry Fuel Storage Area consists of 218 underground silos which store fuel deemed unsuitable for underwater storage. These vaults are constructed of concrete and steel and include liquid intrusion or gas buildup monitoring systems.

    9. 9 ICP – TSR Violations and Enhanced Oversight and Recovery for Spent Fuel Operations CPP-1774 Independent Spent Fuel Storage Installation (ISFSI)

    10. 10 ICP – TSR Violations and Enhanced Oversight and Recovery for Spent Fuel Operations All spent fuel handling operations are completed by contractor personnel assigned to one of five (5) operating crews under the Nuclear Material Disposition (NMD) Project. Crews are on a rotating 4/12 shift cycle A Plant Shift Manager (PSM) is responsible for all operations at INTEC for a shift. Each NMD crew consists of: Operations Supervisor 4 to 6 qualified operators 1 Radiological Controls Technician (RCT)

    11. 11 ICP – TSR Violations and Enhanced Oversight and Recovery for Spent Fuel Operations All spent fuel operations are conducted using detailed operating procedures that incorporate the applicable documented safety analysis Technical Safety Requirements (TSR). TSR hands off to Contractor Approved Fuels List (CAFL) and Contractor Approved Cask List (CACL) which state the criticality controls for fuel handling, storage and loading in various transfer casks are based upon: - fuel type(s) - spacing between fuel(s) criticality barriers storage in air or water cask

    12. 12 ICP – TSR Violations and Enhanced Oversight and Recovery for Spent Fuel Operations Between 11 SEP 08 and 12 OCT 08, the contractor had four separate fuel handling events related to a lack of rigor in disciplined operations EM-ID--CWI-FUELRCSTR-2008-0006, Technical Safety Requirement (TSR) Violation EM-ID--CWI-FUELRCSTR-2008-0007, Spent Fuel Relocated to Incorrect Port EM-ID--CWI-FUELRCSTR-2008-0008, Procedure Violation Results in Radiological Contamination Near Miss EM-ID--CWI-FUELRCSTR-2008-0009, Use of Out Of Service Tool for Fuel Handling in CPP-603

    13. 13 ICP – TSR Violations and Enhanced Oversight and Recovery for Spent Fuel Operations Results in fifth ORPS report: EM-ID--CWI-FUELRCSTR-2008-0010, INTEC Management Review Identifies Recurring Fuel Handling Events Communications less than adequate Procedural use/compliance Human performance, skill based error Management problem, management policy guidance / expectations not well defined, understood or enforced

    14. 14 ICP – TSR Violations and Enhanced Oversight and Recovery for Spent Fuel Operations Contractor actions taken: - Establish 24/7 Senior Supervisory Watches on critical steps Procedure review team Subject Matter Expert (SME) support Training on: Management expectations and policy Procedure use Communications Verifications

    15. 15 ICP – TSR Violations and Enhanced Oversight and Recovery for Spent Fuel Operations DOE-ICP actions taken: Perform a “For Cause” review of fuel handling operations for 2 months Establish 24/7 oversight presence in the field to evaluate management oversight effectiveness (Mentor and SSW), procedure use, communications and performance of verifications Fed observations and issues through the Mentors and SSW for feedback and immediate correction Used standardized checklists

    16. 16 ICP – TSR Violations and Enhanced Oversight and Recovery for Spent Fuel Operations Results of Contractor & DOE corrective actions: Improvement in communications Improvement in verification performance Improvement in procedure content and use Improved understanding of management expectations / policy Identification of some supervisors who were willing to take “risks”

    17. 17 ICP – TSR Violations and Enhanced Oversight and Recovery for Spent Fuel Operations 3 March - EM-ID--CWI-FUELRCSTR-2008-0011, Technical Safety Requirement (TSR) Violation: Procedural compliance Miscommunications Verifications “Pushed ahead” (same Operations Supervisor identified by Mentors as the “At-Risk” supervisor)

    18. 18 ICP – TSR Violations and Enhanced Oversight and Recovery for Spent Fuel Operations Contractor Recovery Plan: Mentor program re-instituted (early) SSW Extent of Conditions (EOC) team formed Quality Assurance (QA) observation of TSR steps in procedures

    19. 19 ICP – TSR Violations and Enhanced Oversight and Recovery for Spent Fuel Operations FMDP Conduct of Operations Assessment results: Conducted 15 February - 30 March 7 Findings and 8 Observations No leading indicators, usual smattering of deviations. Conduct of Operations program rated as “effectively implemented with some areas noted for improvement”

    20. 20 ICP – TSR Violations and Enhanced Oversight and Recovery for Spent Fuel Operations INTEC is currently in a 6-8 month cycle of ORPS events Actions being taken to “break the cycle”: Attempting to identify “lower level” indicators Contractor Assurance System Performance Metrics - CASPM Work Observation Teams (WOT) and Management Work Visits (MWV) Lack of senior contractor management presence except in a “reaction mode”

    21. 21 ICP – TSR Violations and Enhanced Oversight and Recovery for Spent Fuel Operations Questions?

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