DCL-13-094, and Humboldt Bay Power Plant, 10 CFR 71.95 Reports Regarding Energysolutions' Model 8-120B Shipping Cask

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and Humboldt Bay Power Plant, 10 CFR 71.95 Reports Regarding Energysolutions' Model 8-120B Shipping Cask
ML13274A634
Person / Time
Site: Diablo Canyon, Humboldt Bay, 07109168
Issue date: 09/30/2013
From: Halpin E
Pacific Gas & Electric Co
To: Mark Lombard
Document Control Desk, NRC/FSME, Office of Nuclear Material Safety and Safeguards
References
DCL-13-094, HBL-13-014
Download: ML13274A634 (10)
v • d • e


Text

Pacific Gas and Electric Company Edward D. Halpin Diablo Canyon Power Plant Senio r Vice President Mail Code 104/6 Nuclear Generation & Chief Nuclear Officer P. O. Box 56 Avila Beach, CA 93424 805 . 545.4100 September 30 , 2013 E-Mail: E1H8@pge.com PG&E Letter DCL-13-094 PG&E Letter HBL-13-014 Mr. Mark Lombard, Director 10CFR71.95 Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington DC 20555-0001 ATTN: Document Control Desk Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon, Units 1 and 2 Docket No. 50-133, OL-DPR-7 Humboldt Bay Power Plant, Unit 3 Diablo Canyon Power Plant and Humboldt Bay Power Plant 10 CFR 71.95 Reports Regarding EnergySolutions' Model 8-120B Shipping Cask

Dear Mr. Lombard:

Pacific Gas and Electric Company (PG&E) hereby submits the enclosed reports pursuant to 10 CFR 71.95(a)(3) regarding instances in which the conditions of approval in Certificate of Compliance Number 9168 for EnergySolutions' Model 8-120B shipping cask were not met when making radwaste shipments from the Diablo Canyon Power Plant (Enclosure 1) and Humboldt Bay Power Plant (Enclosure 2). These reports are based on our discovery of the potential condition on July 31, 2013.

PG&E makes no new or revised regulatory commitments (as defined by NEI 99-04) in this report. PG&E will implement corrective actions in accordance with the site Corrective Action Program.

If you have any questions concerning this submittal, please contact Mr. Tom Baldwin at 805-545-4720.

Sincerely,

.J5C#j ~ 4IL-fZv Edward D. Halpin A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

  • Comanche Peak
  • Diablo Canyon
  • Palo Verde
  • San Onofre
  • Wolf Creek

Document Control Desk PG&E Letter DCL-13-094 September 30 , 2013 PG&E Letter HBL-13-014 Page 2 J8L3/4486/50576370 Enclosures cc/enc: James Harris, EnergySolutions John Hickman - NRC NRR Project Manager Thomas R. Hipschman, NRC Senior Resident Inspector Jennivine K. Rankin, NRC NRR Project Manager Steven A. Reynolds, Acting NRC Region IV Administrator INPO Diablo Distribution HBPP Humboldt Distribution A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

  • Comanche Peak
  • Diablo Canyon
  • Palo Verde
  • San Onofre
  • Wolf Creek

Enclosure 1 PG&E Letter DCL-13-094 PG&E Letter HBL-13-014 Page 1 of 4 Diablo Canyon Power Plant 10 CFR 71.95 Report Regarding EnergySolutions' Model 8-1208 Shipping Cask

1. Abstract:

This report provides information required by 10 CFR 71.95, "Reports," for instances in which the conditions of approval in Certificate of Compliance (CoC) Number 9168, issued to EnergySolutions, LLC (EnergySolutions) , for its Model 8-120B shipping cask, were not observed in making radioactive waste shipments. The circumstances described in this report apply specifically to Pacific Gas and Electric Company's (PG&E's) Diablo Canyon Power Plant (DCPP). On July 31,2013, DCPP identified 12 shipments that failed to comply with the recently interpreted, vent port leak test requirements associated with the subject CoCo Specifically, Condition 11 in the CoC required a preshipment leak test for Type B quantities. Although the vendor's cask procedure TR-TP-002, "Air Pressure Drop Test For Model 8-120B Cask CoC 9168," specified a 20-minute air pressure-drop leak test for the vent port, the Model 8-120B cask Safety Analysis Report (SAR) Addendum cited a 1-hour air leak test for the primary and secondary lids but was silent on the time for the vent port and drain plug leak test. PG&E now recognizes that the vent port described in the Model 8-120B cask SAR Addendum requires a 1-hour leak test.

Between 2001 and 2008, DCPP made 12 Type-B shipments with this cask and removed the cask vent port plug each time. After replacing the vent port plug, DCPP leak tested the vent port in accordance with PG&E's Maintenance Procedure (MP) M-50.23, "Loading Pre-Loaded Liners Into The Chem-Nuclear CNS 8-120B Radioactive Waste Shipping Cask," and the vendor's cask procedure which specified a 20-minute hold time. This hold time is not consistent with the 1-hour hold time identified in the Model 8-120B SAR Addendum for the shipping cask and thus constitutes a noncompliance with the CoCo There were no components or system failures that contributed to this event.

2. Narrative Description of Event The Model 8-120B shipping cask is a cylindrical, carbon steel, lead-shielded packaging designed for the transport of radioactive waste containers. The cask has both a full-opening primary lid and a smaller, inner-secondary lid. Test ports for leak testing these package lids are located between the twin a-ring seals for both the primary and secondary lids. Each package has a vent and optional drain port which can be used to inert the cask cavity with nitrogen, or vent pressure within the containment cavity which may be generated during transport, prior to lid removal. The vent hole in the primary lid is sealed with a removable plug and silicone gasket. There are no complex operational requirements associated with the package. An air test rig with a pressure gauge is bolted above each of the test ports or vent hole to pressurize the cavity. During leak

Enclosure 1 PG&E Letter DCL-13-094 PG&E Letter HBL-13-014 Page 2 of 4 testing, the air supply is isolated and the gauge is monitored to ensure a pressure drop of no more than 1 pound-per-square-inch over the test period.

MP M-50.23 specified a 20-minute hold time for the preshipment leak test of the cask vent port, which was successfully completed for all 12 shipments. However, DCPP now recognizes the Model 8-120B cask SAR to require a hold time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for the leak test of the vent port. Therefore, the conditions of approval in the CoC were not met when making these shipments. This failure to comply was identified on July 31,2013, during a radioactive waste peer group teleconference that discussed EnergySolutions' investigation into this potential discrepancy between its procedure, DCPP site procedures, and the Mode18-120B cask SAR Addendum.

i. Status of inoperable components or systems Not applicable. None of the components or systems were inoperable.

ii. Dates and approximate times of occurrences The testing for these 12 shipments occurred between March 2001 and June 2008.

iii. Cause of Error Procedure discrepancies regarding adequate air pressure-drop leak test hold time requirements between DCPP Procedure MP M-50.23, EnergySolutions' Procedure TR-TP-002, and the Mode18-120B cask SAR Addendum.

iv. Failure Mode, Mechanism, and Effects Not applicable.

v. Systems or Secondary Functions Affected Not applicable.

vi. Method of Discovery of the Error The specific i-hour leak test requirement was identified during a peer discussion about EnergySolutions' notice to the industry on this issue.

vii. Discussion of Cause Procedure discrepancies regarding adequate hold-time requirements between DCPP MP M-50.23, EnergySolutions' Procedure TR-TP-002, and the Model 8-120B cask SAR Addendum.

Enclosure 1 PG&E Letter DCL-13-094 PG&E Letter HBL-13-014 Page 3 of 4 viii. Manufacturer and Model Number Manufacturer: EnergySolutions, LLC Model Number: 8-120B ix. Quantities and chemical and physical form(s) of the package contents These shipments were all PhysicallChemical form Solid/Oxides on resin. The quantities were as shown in the table below.

Quantity Date (Curies) 162 RWS-01-001 03/07/01 376 RWS-01-002 03/23/01 85 RWS-02-001 01/17/02 177 RWS-02-002 04/11/02 113 RWS-03-003 06/05/03 RWS-04-001 01/23/04 60.6 62 RWS-04-002 02/05/04 203 RWS-05-002 03/10105 137 RWS-06-001 01/26/06 91 RWS-06-003 11/09/06 RWS-07-001 02/07/07 130 RWS-08-002 06/05/08 144

Enclosure 1 PG&E Letter DCL-13-094 PG&E Letter HBL-13-014 Page 4 of 4

3. Assessment of Safety Consequences Based on the safety evaluation conducted by EnergySolutions, there is no safety consequence of performing the preshipment leak test of the Model 8-120B cask vent port using a 20-minute hold time versus the 1-hour hold time.
4. Corrective Actions PG&E is reviewing the need to use this cask in the future. If used in the future, DCPP will revise MP M-50.23 prior to using it. EnergySolutions revised Procedure TR-TP-002 to be in alignment with the Mode18-120B SAR Addendum.
5. Previous Similar Events None.
6. Contact for Additional Information Clint Miller, DCPP Radwaste Engineer, 805-545-4582.
7. Extent of Exposure of Individuals to Radiation or Radioactive Materials The vent port was adequately sealed, and there was no additional exposure of individuals to radiation or radioactive material as the result of the reduced leak-test time.

Enclosure 2 PG&E Letter DCL-13-094 PG&E Letter HBL-13-014 Page 1 of 4 Humboldt 8ay Power Plant 10 CFR 71.95 Report Regarding EnergySolutions' Model 8 ..1208 Shipping Cask

1. Abstract:

This report provides information required by 10 CFR 71.95, "Reports," for instances in which the conditions of approval in Certificate of Compliance (Co C) Number 9168, issued to EnergySolutions, LLC (EnergySolutions) , for its Model 8-120B shipping cask, were not observed in making radioactive waste shipments. The circumstances described in this report apply specifically to Pacific Gas and Electric Company's (PG&E's) Humboldt Bay Power Plant (HBPP). HBPP identified two shipments that failed to comply with the recently interpreted, vent port leak test requirements associated with the subject CoCo Specifically, Condition 11 in the CoC required a pre-shipment leak test for Type B quantities. Although the vendor's cask procedure TR-TP-002, "Air Pressure Drop Test For Model 8-120B Cask CoC 9168," specified a 20-minute air pressure-drop leak test for the vent port, the Model 8-120B cask Safety Analysis Report (SAR) Addendum cited a 1-hour air leak test for the primary and secondary lids but was silent on the time for the vent port and drain plug leak test. HBPP recognizes that the vent port described in the Model 8-120B cask SAR Addendum requires a 1-hour leak test.

HBPP made two Type-B shipments with this cask and removed the cask vent port plug each time. After replacing the vent port plug, HBPP leak tested the vent port in accordance with HBPP Work Order Number 354 for the subject shipments and the referenced vendor's cask procedure which, specified a 20-minute hold time. This hold time is not consistent with the 1-hour hold time identified in the Model 8-120B cask SAR Addendum for the shipping cask and thus constitutes a noncompliance with the CoCo There were no components or system failures that contributed to this event.

2. Narrative Description of Event The Model 8-120B shipping cask is a cylindrical, carbon steel, lead-shielded packaging designed for the transport of radioactive waste containers. The cask has both a full-opening primary lid and a smaller, inner-secondary lid. Test ports for leak testing these package lids are located between the twin O-ring seals for both the primary and secondary lids. Each package has a vent and optional drain port which can be used to inert the cask cavity with nitrogen, or vent pressure within the containment cavity which may be generated during transport, prior to lid removal. The vent hole in the primary lid is sealed with a removable plug and silicone gasket. There are no complex operational requirements associated with the package. An air test rig with a pressure gauge is bolted above each of the test ports or vent hole to pressurize the cavity. During leak testing, the air supply is isolated and the gauge is monitored to ensure a pressure drop of no more than 1 pound-per-square-inch over the test period.

Enclosure 2 PG&E Letter DCL-13-094 PG&E Letter HBL-13-014 Page 2 of 4 The HBPP Work Orders utilized the EnergySolutions cask procedure with a specified 20-minute hold time for the preshipment leak test of the cask vent port. The 20-minute test passed for both shipments. However, HBPP now recognizes the Model 8-120B cask SAR to require a hold time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for the leak test of the vent port. Therefore, the conditions of approval in the CoC were not met when making these shipments. This failure to comply was identified on July 31,2013, during a radwaste peer group teleconference that discussed EnergySolutions' investigation into this potential discrepancy between its procedure and the Mode18-120B cask SAR Addendum.

i. Status of inoperable components or systems Not applicable. None of the components or systems were inoperable.

ii. Dates and approximate times of occurrences The testing for the two shipments occurred between September 2012 and November 2012.

iii. Cause of Error Procedure discrepancies regarding adequate air pressure-drop leak test hold time requirements between HBPP Work Orders, EnergySolutions' Procedure TR-TP-002, and the Mode18-120B cask SAR Addendum.

iv. Failure Mode, Mechanism, and Effects Not applicable.

v. Systems or Secondary Functions Affected Not applicable.

vi. Method of Discovery of the Error The specific 1-hour leak test requirement was identified during a peer discussion about EnergySolutions' notice to the industry on this issue.

Enclosure 2 PG&E Letter DCL-13-094 PG&E Letter HBL-13-014 Page 3 of 4 vii. Discussion of Cause Procedure discrepancies regarding adequate hold-time requirements between HBPP Work Orders, EnergySolutions' Procedure TR-TP-002, and the Model 8-1208 cask SAR Addendum.

viii. Manufacturer and Model Number Manufacturer: EnergySolutions, LLC Model Number: 8-120B ix. Quantities and chemical and physical form(s) of the package contents These shipments were all Physical/Chemical form Solid/Oxides. The quantities were:

Date Quantity (Curies)

RMS-12-118 - ISC18 Processing 9/17/12 48.3 RMS-12-163 - RVI Disposal 11/27/12 280

3. Assessment of Safety Consequences Based on the safety evaluation conducted by EnergySolutions, there is no safety consequence of performing the preshipment leak test of the Model 8-120B cask vent port using a 20-minute hold time versus a 1-hour hold time.
4. Corrective Actions The HBPP Work Order was revised to reference the EnergySolutions revised Procedure TR-TP-002. The revised procedure preshipment leak test of the Model 8-120B cask vent port uses a 1-hour hold time as required by the CoC to be in alignment with the Mode18-120B cask SAR Addendum. '

,5. Previous Similar Events None.

6. Contact for Additional Information John Kristofszki, HBPP Manager Strategic Waste Disposal, 707 382-8720.

Enclosure 2 PG&E Letter DCL-13-094 PG&E Letter HBL-13-014 Page 4 of 4

7. Extent of Exposure of Individuals to Radiation or Radioactive Materials The vent port was adequately sealed and there was no additional exposure of individuals to radiation or radioactive material as the result of the reduced leak-test time.
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