05000285/FIN-2015004-01
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Finding | |
|---|---|
| Title | Licensee-Identified Violation |
| Description | Title 10 CFR 72.174 requires that each licensee maintain sufficient records to furnish evidence of activities affecting quality. Records pertaining to the design, fabrication, erection, testing, maintenance, and use of structures, systems, and components important to safety must be maintained by or under the control of the licensee until the NRC terminates the license. Contrary to the above, as of June 21, 2013, Fort Calhoun failed to maintain sufficient records to furnish evidence of activities affecting quality. Specifically, the licensee did not maintain records for loading activities associated with DFS-HSM-06 that was placed on the ISFSI pad in July of 2009. This violation was identified by FCS and placed in their corrective action program (CR 2013-12884). The fuel assembly data was reconstituted based on records from the Reactor Engineering group, and the canister helium leak-test data was reconstituted based on the helium leak-test technician's field notes. The remaining canister records associated with the canister processing, sealing, and transportation to the ISFSI, including several TS requirements, were not found. Fort Calhoun reconstituted the fuel and helium leak test data and conducted interviews with cask loading personnel to conclude that there was no evidence to suggest that loading activities did not comply with the licensee's procedures and the licensed Technical Specifications. This violation did not have any safety impact because all fuel assemblies met the requirements for burn-up, decay heat, and cooling time and the licensee demonstrated that the canister integrity was intact based on the reconstituted helium leak test records. All the fuel inside the canister and the cask remain in a safe condition. This finding was reviewed by NRC Headquarters Division of Spent Fuel Managements Spent Fuel Licensing Branch. Based on the reconstituted records and interviews with the dry fuel loading staff, the NRC found no evidence to demonstrate that the canister did not meet the required license conditions and as such, found the canister acceptable for continued storage under FCSs general Part 72 license. However, though the canister is acceptable for storage, the licensee must track this issue to identify that further analyses may be required for this canister to meet all applicable Part 71 requirements to be acceptable for transportation. In accordance with the NRC Enforcement Policy Section 2.2 and IMC 0612 Section 03.23, Part 72 ISFSI inspection findings follow the traditional enforcement process and are not dispositioned through the Reactor Oversight Process or the Significance Determination Process. The violation screened as having very low safety significance, Severity Level IV, and is being treated as a non-cited violation, consistent with Section 2.3.2.a. of the Enforcement Policy. The violation was determined to be more than minor since the licensee failed to establish, maintain, or implement adequate controls over procurement, construction, examination, or testing processes that are important to safety. The violation was entered into the licensees corrective action program as CR 2013-12884. Following identification of the issue the licensee performed an assessment that showed the cask would continue to perform its design function. Corrective actions for this issue included performing an extent of condition review, performing an apparent cause analysis report, reconstitution of the missing documents, conducting interviews with the dry cask loading personnel, providing training to the staff involved, and changing processes and responsibilities within FCS Records Management Group. |
| Site: | Fort Calhoun  |
|---|---|
| Report | IR 05000285/2015004 Section 4OA7 |
| Date counted | Dec 31, 2015 (2015Q4) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | B Cummings E Simpson G Miller J Kirkland J Melfi J O'Donnell L Brookhart L Carson M Chambers P Jayroe S Schneider |
| Violation of: | Technical Specification - Procedures Technical Specification License Condition |
| INPO aspect | |
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Finding - Fort Calhoun - IR 05000285/2015004 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Fort Calhoun) @ 2015Q4
Self-Identified List (Fort Calhoun)
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