IR 05000387/1999008
| ML17165A044 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/07/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17165A043 | List: |
| References | |
| 50-387-99-08, 50-388-99-08, NUDOCS 9910220027 | |
| Download: ML17165A044 (24) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION REGION I
Docket Nos:
License Nos:
50-387, 50-388 NPF-14, NPF-22 Report No.
50-387/99-08, 50-388/99-08 Licensee:
PP&L; Inc.
2 North Ninth Street Allentown, Pennsylvania 19101 Facility:
Susquehanna Steam Electric Station Location:
P.O. Box 35 Berwick, PA 18603-0035 Dates:
July 6, 1999 through September 2, 1999 Team Leader:
Inspectors:
E. H. Gray, Senior Reactor Engineer Engineering Support Branch Division of Reactor Safety S. Baggett, SFPO Project Manager A. Blarney, Resident Inspector P. Frechette, Security Specialist J. McFadden, Radiation Specialist S. Hansell, Senior Resident Inspector J. Richmond, Resident Inspector D. Silk, Senior Emergency Preparedness Specialist Approved by:
William H. Ruland, Chief Engineering Support Branch Division of Reactor Safety 99i0220027 99i007 PDR ADQCK 05000387
EXECUTIVESUMMARY Susquehanna Steam Electric Station (SSES), Units 1 B 2 NRC Inspection Report 50-387/99-08, 50-388/99-08 This inspection was to observe and review the preparations of PPB L to move spent fuel from the spent fuel pool to the independent spent fuel storage'installation (ISFSI) located at the plant site.
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Based on the review of completed procedures and work packages, the detailed 10 CFR 72.212 evaluation documentation that compares the specifics of the Susquehanna site ISFSI project to that licensed by NRC, the extent of planning, and the overall effectiveness of the PPB L ISFSI project management, PPB L was found to be meeting the significant terms and conditions of the Certificate of Compliance (CoC), and 10 CFR Parts 50 and 72 as they related to the ISFSI and was adequately prepared to use the ISFSI (Section 1 ).
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During the independent spent fuel storage installation (ISFSI) dry run the PPB L ISFSI staff properly denionstrated the equipment, procedures, planning and training of the ISFSI work team members.
When the preparations and dry run exercises identified issues or items for improvement, these were addressed by evaluation and appropriate action.
Issues raised by the inspectors, including establishing a process for the acceptance of the dry run by management, were addressed by PPB L during the course of the inspection.
The dry run demonstrated that the ISFSI staff along with the task equipment and procedures were adequately prepared to initiate the transfer of spent fuel from the spent fuel pool to the horizontal storage module pad area located on the plant site (Section 2).
The operational procedures for the dry cask storage system (DCSS) loading, unloading, and transfer activities and the acceptance criteria met ISFSI program needs and regulatory requirements'.
The operational procedures covered the full scope of major activities involved in loading, unloading, and fuel transfer and were highly detailed.
The procedures were prepared, reviewed, and approved in accordance with the licensee's administrative program for document control (Section 3 ).
The licensee's methods for verifying and documenting the parameters and characteristics of spent fuel placed in the dry shielded canister per the Certificate of Compliance was satisfactory, based on the review of selected portions of Procedure RE-081-043, Selection and Monitoring of Fuel for Dry Storage.
This procedure required multiple and independent verification and documentation of the parameters and characteristics of spent fuel placed in the dry shielded canister (Section 4 ).
Adequate procedures reflecting the requirements of 10 CFR parts 50.59 and 72.48 for changes, tests and experiments were established for performing design changes or evaluating nonconformance conditions (Section 6).
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The preparations for welding of the dry shielded canister welds, including training and qualification of the welders, were thorough.
The quality of the welds were excellent including weld process parameter control, the visual appearance of each weld pass and the final as-welded surface as verified by dye penetrant testing.
The capability to cut through the completed welds should a DSC need to be unloaded was demonstrated.
The penetrant examination method for testing welds met the procedural requirements and industry standards (Section 7 ).
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The licensee's plans and preparations for controlling radiological activities for the ISFSI were extensive and detailed.
Specific radiation work permits (RWPs) with appropriate radiological controls included were available.
Health physics technicians were observing the dry run activities, anticipating radiation conditions and providing countermeasures to the ISFSI work staff. The ISFSI operational procedures had been reviewed by radiation protection personnel and contained cautionary notes for specific radiological hazards (Section 8).
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The Susquehanna site existing Emergency Preparedness Program was not significantly affected by the ISFSI project activities. Because the spent fuel storage facilitywas located within an existing Protected Area (PA) that met all regulatory requirements and was compliant with the NRC approved Physical Security Plan (the Plan), no additional security provisions for the spent fuel storage facilitywere required (Sections 9 and 10 ).
The training program for personnel involved with the ISFSI activities was implemented appropriately.
The Certificate of Compliance requirement that training should include an overview, radiological safety issues, off normal event procedures, and licensing requirements was met. Criteria for determining which individuals required training were adequate.
ISFSI operations personnel were given specialized training in the equipment and procedures.
In numerous cases, hands-on simulation to demonstrate an ability to conduct the activities was conducted.
The training of HP technicians for the radiological aspects of the ISFSI evolutions was performed in a thorough manner based on the detailed training materials used and on their involvement in the dry runs (Section 11).
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The Certificate of Compliance requirements for heavy loads and for maximum handling height for the loaded TC/DSC were adequately addressed based on appropriate procedures being in place, including procedures for qualification of crane operators, on the independently verified operable condition of the single-failure-proof crane, on the quality control measures on the ISFSI rigging, and on the documentation of the safe load path (Section 12 ).
TABLEOF CONTENTS PAGE 1.
Management, Organization, Responsibilities, Self-Assessments, and Corrective Actions 2.
Dry Run Operations and Preparation for Cask Loading 3.
Procedures, Document Controls, 8 Records..
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Fuel Verification 5.
Quality Assurance and Quality Control 6.
Design Change Reviews 7.
Welding/Non-Destructive Testing
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Health Physics 9.
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Security 11.
Training
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Rigging, Control of Heavy Loads, and Crane Operations.
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Planning for Off-Normal Events
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.. 13 14.
Exit Meeting Summary
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Re ort Details INana ement Or anization Res onsibilities Self-Assessments and Corrective Actions Ins ection Sco e 60854 The inspectors evaluated whether the licensee was adequately prepared to use the independent spent fuel storage installation (ISFSI) located onsite and whether the significant legal and practical commitments were met by their plans, work packages, work practices, procedures and provisions for documentation.
Specially addressed was the status of PP8L in meeting the terms and conditions of the Certificate of Compliance (CoC) for the ISFSI project, and 10 CFR Parts 50 and 72 as they relate to the ISFSI.
Observations and Findin s The inspector reviewed the PP8 L 72.212 evaluation to determine adequacy of the review and ifthe conditions of 10 CFR 72.210, the CoC and the CSAR had been addressed.
The evaluation was clear, concise and referenced applicable PP&L procedures, and no further supporting evaluations were necessary.
The inspector did identify one issue (i.e., fuel integrity) for which PP&L subsequently provided further analysis.
The CoC was conditioned to authorize only spent fuel that was free of gross defects.
PP8L provided an analysis that the greater than 10-year-old spent fuel met this condition because of the operating performance of the fuel, the practices used to handle the assemblies, the original inspection of the fuel assemblies, and the chemical environment within which the spent fuel assemblies were stored.
Conclusions Based on the review of completed procedures and work packages, the detailed 10 CFR 72.212 evaluation documentation that compares the specifics of the Susquehanna site ISFSI project to that licensed by NRC, the extent of planning, and the overall effectiveness of the PP8L ISFSI project management, the licensee was found to be meeting the significant terms and conditions of the Certificate of Compliance (CoC), and 10 CFR Parts 50 and 72 as they related to the ISFSI and was adequately prepared to use the ISFSI.
D Run 0 erations and Pre aration for Cask Loadin Ins ection sco e 80654 The inspectors observed samples of the preoperational testing or dry run of ISFSI operations, reviewed portions of the applicable procedures and work instructions and discussed the process with those involved.
Observations and findin s The objective of the dry run was to demonstrate that the ISFSI staff was adequately trained and that the equipment and procedures were ready for spent fuel movement.
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also provided experience in the performance of work tasks for those involved. To avoid radiological contamination of the dry shielded canister (DSC) during the dry run
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exercises it was not filled with reactor fuel pool wate'r or placed under fuel pool water in the cask pit during the demonstration process.
Also, the movement of spent fuel was not a part of the dry run as fuel transfer from the fuel pool to the DSC is to be done by the crews that normally perform fuel moves.
The dry run was conducted in two major steps.
First, the individual operations were performed by the three work crews over a several week period. As expected, the dry run process identified minor problems with equipment and procedures that were best found during the preparations for the dry run and its conduct.
Work practices were improved, equipment deficiencies were identified and corrected and procedures were updated.
The second part of the dry run was a final exercise through the process steps to demonstrate readiness to transfer spent fuel from the fuel pool to the horizontal storage module (HSM). This did not include submersion of the transfer cask or DSC in the spent fuel pool water.
Issues identified by the inspectors included: how the separate dry run activities would be coordinated to result in a smoothly running first fuel transfer; a definition of the process to be used by PP8 L to decide that the dry run was acceptable and that management was satisfied with the extent of the dry run activities; the determination of boiling time from decay heat during the interval between the loading of a canister with spent fuel to the draining of water; and preparations and contingencies for special actions related to-cold weather.
These issues and other questions raised by the inspectors were addressed by PPBL during the course of the inspection.
The PPBL ISFSI task team was satisfied with the adequacy of the dry run process and presented the basis for this conclusion to the plant PORC meeting for management approval on August 2?, 1999.
Conclusions During the independent spent fuel storage installation (ISFSI) dry run the PP8L ISFSI staff properly demonstrated the equipment, procedures, planning and training of the ISFSI work team members.
When the preparations and dry run exercises identified issues or items for improvement, these were addressed by evaluation and appropriate action. Issues raised by the inspectors, including establishing a process for the acceptance of the dry run by management, were addressed by PP8L during the course of the inspection.
The dry run demonstrated that the ISFSI staff along with the task equipment and procedures were adequately prepared to initiate the transfer of spent fuel from the spent fuel pool to the horizontal storage module pad area located on the plant sit.
Procedures Document Controls & Records a.
Ins ection Sco e 60854 The inspectors reviewed selected portions of the following operational procedures for the dry cask storage system (DCSS) loading, unloading, and transferring activities. This sampling was to determine ifthe procedures provided clear instructions to users, established limitations and action levels, directed the workers on what to do ifunsafe conditions arose, and provided for clear recognition when an NRC commitment activity was being performed such as an SAR commitment.
The inspectors selectively verified that the operational procedures for DCSS loading, unloading, and transferring activities and their acceptance criteria met the requirements and commitments specified in the DCSS Safety Analysis Report (SAR), Safety Evaluation Report (SER), Certificate of Compliance (CoC)(Certificate No.1004, Standardized Nuclear Horizontal Modular Storage (NUHOMS) System, Model No. NUHOMS-52B for Boiling Water Reactor Fuel),
the licensee's Quality Assurance (QA) program, and 10 Code of Federal Regulations (CFR) Part 72. The inspectors selectively verified that the operational procedures for the DCSS activities had been prepared, reviewed, and initiallyapproved in accordance with the licensee's administrative programs.
Document control was assessed to assure that processes for procedures and their requirements for design change reviews were clearly explained.
NDAP-QA-0658, Dry Fuel Storage (DFS)
ME-ORF-141, Dry Fuel Storage-Transport and Preparation of Transfer Cask (TC)
and Dry Shielded Canister (DSC) for Loading Fuel ME-ORF-142, Dry Fuel Storage-Transport and Loading of Transfer Cask and DSC ME-ORF-143, Dry Fuel Storage-Transport of Loaded Transfer Cask and DSC to Transfer Trailer ME-ORF-144, Dry Fuel Storage-DSC Draining, Vacuum Drying, and Helium Fill ME-ORF-145, Dry Fuel Storage-Loaded DSC Welding ME-ORF-146, Dry Fuel Storage-Transport and Alignment of Transfer Cask to Horizontal Storage Module (HSM)
ME-ORF-147, Dry Fuel Storage-Loading of HSM with DSC ME-ORF-148, Dry Fuel Storage-Restoration of an HSM/Transfer Trailer and Transport of Transfer Trailer to 101 Door ME-ORF-150, Dry Fuel Storage-DSC Unloading Procedure ON-081-001, Fuel Handling Accident ON-081-002, Refueling Platform Operation Anomaly RE-081-043, Selection and Monitoring of Fuel for Dry Storage Information was gathered through observation of work, including the dry run activities required by the CoC, tours of the affected areas, discussions with cognizant personnel, and review and evaluation of procedures and document b.
Observations and Findin s The operational procedures were detailed and covered the full scope of major activities involved in loading, unloading, and fuel transferring.
The procedures and their acceptance criteria were verified to have adequately addressed selected requirements in the DCSS's SAR, SER, CoC, the licensee's QA program, and 10 CFR 72. A licensee document, Susquehanna Steam Electric Station (SSES) Spent Fuel Storage Project 10CFR72.212 Evaluation (Rev. 0), addressed their review of these requirements and their determination of how compliance had been implemented in the case of each requirement.
This document was well organized and thorough.
The inspectors selectively verified that the operational procedures for the DCSS activities had been prepared, reviewed, and initiallyapproved in accordance with the licensee's administrative programs.
Document control was in place for the development, scheduling, approval and issuance of the procedures.
PP8L also had a process in place for the developer of the procedure to get direct feedback from the user.
PP8 L procedure owners planned group meetings with the procedure users to discuss any needed changes or clarifications. The licensee had verified draft procedures by witnessing independent spent fuel storage installation (ISFSI) activities at other sites and by internal procedure reviews. The ISFSI team validated the approved procedures by their trial use during the dry run evolutions at SSES.
The licensee used multiple procedures, and the procedures overlapped sufficiently so that all required major critical activities were addressed.
The procedures had a sufficient level of detail, hold points and sign offs to provide clear instructions to the workers, and they contained CoC and other licensing requirements associated with the procedures'cope and purpose.
Cautionary personnel safety notes were placed in appropriate places in the procedures.
The inspector identified a concern regarding the initial proposed location of the hydrogen monitor. Ifthe hydrogen monitoring system was located as depicted in the attachment to the procedure and ifhydrogen generation were to become a problem, the hydrogen level at the area of the welders could exceed the safe level (4%) before the hydrogen monitor would alarm.
PP&L staff agreed that the location of the hydrogen monitor would need to be reevaluated and appropriate changes made.
The revised hydrogen monitoring arrangement was noted to be a functional improvement.
In addition, PP&L planned to use a combination of hand-held hydrogen monitors and calculations to demonstrate that hydrogen levels were safe during welding operations.
Conclusions The operational procedures for the dry cask storage system (DCSS) loading, unloading, and transfer activities and their acceptance criteria met ISFSI program needs and regulatory requirements.
The operational procedures covered the full scope of major activities involved in loading, unloading, and fuel transfer and were highly detailed.
The procedures were prepared, reviewed, and approved in accordance with the licensee's administrative program for document contro Fuel Verification Ins ection Sco e 60854 The inspectors reviewed the licensee's methods for verifying and documenting the parameters and characteristics of spent fuel placed in the dry shielded canister per the Certificate of Compliance (CoC). Selected portions of the following procedures were reviewed.
NDAP-QA-0337, Control of Special Nuclear Material RE-081-043, Selection and Monitoring of Fuel for Dry Storage RE-081-036, Core/Fuel Pool Verification Information was gathered through observation of activities, including the dry run activities required by the CoC, tours of the affected areas, discussions with cognizant personnel, and review and evaluation of procedures and documents.
Observations and Findin s Procedure RE-081-043, Selection and Monitoring of Fuel for Dry Storage, provided guidance on selecting fuel assemblies for storage, generating the fuel and core component transfer authorization sheet (FACCTAS) used to transfer fuel assemblies to the cask and monitoring the temperature rise across the horizontal storage modules.
This procedure described the CoC restrictions on fuel assemblies, including the restrictions on initial average fuel enrichment, vendor origin and models, maximum exposure, minimum cooling time, maximum initial uranium content, and on maximum decay heat loading.
As regards the equal to or greater than five years of minimum cooling time (post irradiation time) for fuel, required by the CoC for loading into the NUHOMS-52B DSC, the licensee has decided to load only fuel with a minimum cooling time of equal to or greater than ten years.
The licensee used ten years of cooling time in various nuclear engineering calculations cited in their 10 CFR 72.212 evaluation document and noted this decision in Procedure RE-081-043.
This procedure also provided guidance on monitoring, following initial DSC transfer to the HSM, the numerical difference between the ambient air temperature and the HSM air outlet vent temperature until the equilibrium air temperature difference was reached and for verifying that the actual temperature was less than the calculated/expected temperature rise. The procedure included actions to be taken ifthe actual temperature rise exceeded that expected.
The procedure stated that the CoC allowed only non-consolidated, zircaloy-clad fuel with no known or suspected gross breaches.
A pool verification, of assemblies intended to be loaded into casks, was required in accordance with procedure RE-081-036.
Preparation of a FACCTAS in accordance with NDAP-QA-0337, to control the loading of fuel into the DSC, was also required.
Immediately prior to insertion of a spent fuel
assembly into the dry shielded canister (DSC), the identity of the assembly must be confirmed. After the loading of the DSC, the identity (i.e., serial number) and location of each fuel assembly must be verified and videotaped.
Quality control and reactor engineering personnel must review the videotape of the DSC loading and verify that the DSC loading was correct. Additionally, notification to the NRC, in accordance with 10CFR72.212, within 30 days of storing fuel in a DSC and registering the use of a DSC to store fuel was required by this procedure.
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Conclusions The licensee's methods for verifying and documenting the parameters and characteristics of spent fuel placed in the dry shielded canister per the Certificate of Compliance was satisfactory, based on the review of selected portions of Procedure RE-081-043, Selection and Monitoring of Fuel for Dry Storage.
This procedure required multiple and independent verification and documentation of the parameters and characteristics of spent fuel placed in the dry shielded canister.
5.
uall Assurance and uall Control a.
Ins ection Sco e 60854 An evaluation was conducted to determine how PPB L implemented its procedures and program to bring to final resolution the stop work order of January 20, 1997, which was issued to Transnuclear West Inc.
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Observations and Findin s By letter dated January 20, 1997, PPB L issued a stop work order to Transnuclear West regarding problems identified by PPB L during its oversight activities conducted during the fabrication ofthe concrete Horizontal Storage Modules (HSMs) at the end of 1996. A PPB L project team consisting of representatives from their technical, contractual and quality assurance organizations assessed TN West's readiness to resume fabrication of the PP&L ISFSI components.
By letter dated November 2, 1998, PPB L acknowledged that fabrication of the ISFSI could be restarted.
PPB L's QA program handled this issue in accordance with its procedures and developed sufficient tracking milestones to assure that TN West fabrication activities would result in products acceptable to the PPB L ISFSI program.
Conclusions The resolution of the PP&L stop work order of January 20, 1997, which was issued to Transnuclear West Inc:, was conducted appropriately by the performance of an assessment by a PP&L project team and appropriate corrective action.
Desi n Chan e Reviews
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a.
Ins ection Sco e 60854 The licensee's 10 CFR 50.59 and 72.48 processes for changes, tests and experiments were reviewed to confirm that a documented and acceptable program was in place for performing design changes or evaluating nonconformance conditions that could affect the ISFSI activities.
b.
Observations and Findin s PP8L's revision of the 50.59 evaluation procedures for the ISFSI project were based on an assumption that the PP8 L staff would not perform any 72.48 evaluations and that all evaluations associated with the ISFSI would either be conducted under 50.59 or be performed by TN-West. PP8L reconsidered this assumption during the inspection and committed to revise procedures to denote that 72.48 applied to the ISFSI, not 50.59.
PP8L developed interim procedures to deal with 72.48 issues until the final modification and approvals could be made to integrate 72.48 provisions into PP8L's 50.59 program.
This approach willensure compliance with 10 CFR 72.48 for changes, tests and experiments where these may affect the ISFSI installation or activities.
Conclusions Adequate procedures reflecting the requirements of 10 CFR parts 50.59 and 72.48 for changes, tests and experiments were established for performing design changes or evaluating nonconformance conditions.
7.
Weldin /Non-Destructive Testin The welding and cutting procedures, welding process, and welder training and qualification for the welding operations performed on the dry shielded canister (DSC)
were observed or reviewed.
b.
Observations and findin s The DSC has an inner cover plate weld, vent and drain cover plate welds and an outer cover plate weld. The primary welding method uses an automated inert gas shielded tungsten arc welding process with cold wire feed that has the capability for minor adjustments by the welder during the welding process. The small diameter vent/drain cover plate welds are to be done using the manual gas tungsten arc process for welding and machine cutting for removal.
The plasma arc process is intended for use in the removal of the main inner and outer cover plate The inspectors observed the welding and cutting of full size assemblies that had the same weld joint preparations as the production DSCs.
Two welders were trained and qualified for each of the three ISFSI work crews. The welding was conducted under Work Authorization 105677.
The visual quality of the welding was excellent and confirmed to be acceptable by liquid penetrant (PT) examination.
The PT examination was observed and noted to be performed in accordance with a qualified procedure.
The qualification records for the welders were reviewed as well as the process for maintaining their qualifications up to date.
The inspector found the preparation and performance of welding to be of high quality. PP8L provided an adequate amount of material for weld process training.
Conclusions The preparations for welding of the dry shielded canister welds, including training and qualification of the welders, were thorough.
The quality of the welds were excellent including weld process parameter control, the visual appearance of each weld pass and the final as-welded surface as verified by dye penetrant testing. The capability to cut through the completed welds should a DSC need to be unloaded was demonstrated.
The penetrant examination method for testing welds met the procedural requirements and industry standards.
Health Ph sics Ins ection Sco e 60854 The inspectors selectively reviewed radiation protection (RP) planning and preparation, radiation work permits, and the specific radiological hazards identified and the controls to be implemented for the dry cask storage system (DCSS) loading, unloading, and transferring activities. Information was gathered through observation of activities, including the dry run activities required by the Certificate of Compliance (CoC), tours of the affected areas, discussions with cognizant personnel, and review and evaluation of procedures and documents.
Observations and Findin s A specific radiation protection group representative was assigned to and was involved with this project from its early stages.
Specific radiological hazards were identified in the operational DCSS procedures, and radiation work permits containing the radiological controls to be implemented were available.
Pre-job health physics briefing packages were prepared, were thorough, and discussed the expected radiological hazards and controls. A list of specific radiological hazards and radiation data, for the highest dose-significant activities of the major evolutions involved, had been prepared and was being used interactively by health physics (HP) technicians and the radiation workers during the dry runs for the HP technicians's and the radiation workers's familiarization. The radiation work permits stated that hot particle controls would be implemented in addition to the routine radiological contamination controls and described the radiation monitoring and alarm systems involved in the various evolutions.
In accordance with 10 CFR
72.212(b)(6), the licensee documented a review of their radiation protection program to determine ifits effectiveness would be decreased by the ISFSI operation.
The licensee determined that the activities involved with the operation and maintenance of the ISFSI
'ould be adequately controlled under current site Technical Specifications and procedures.
Conclusions The licensee's plans and preparations for controlling radiological activities for the ISFSI were extensive and detailed.
Specific radiation work permits (RWPs) with appropriate radiological controls included were available.
Health physics technicians were observing the dry run activities, anticipating radiation conditions and providing countermeasures to the ISFSI work staff. The ISFSI operational procedures had been reviewed by radiation protection personnel and contained cautionary notes for specific radiological hazards.
Emer enc Pre aredness
'ns ection sco e 71750 The 72.212 evaluation was reviewed for significance of ISFSI activities on the overall plant Emergency Preparedness Program Observations and findin s A review of the 10 CFR 72.212(b)(6) evaluation indicated that PP&L had conducted a thorough assessment of the emergency preparedness aspects associated with the ISFSI. Threats to the ISFSI from fire, sabotage, and natural occurrences were covered by existing emergency action levels (EAL). The licensee developed a new EAL specific to the ISFSI. From discussion with the EP manager, the inspector determined that the new EALwas based upon NRC-approved guidance from NUMARC and the licensee obtained the consent of the offsite agencies for the new EAL. The inspector found that ISFSI project as currently planned had no significant impact on EP planning or procedures.
Conclusions The Susquehanna site existing Emergency Preparedness Program was not significantly affected by the ISFSI project activities.
~Securi Ins ection Sco e 81700 Determine whether the conduct of security and safeguards activities for the dry spent fuel storage project which is located inside the owner protected area met the licensee's commitments in the NRC-approved security plan (the Plan) and NRC regulatory requirements.
The security program was inspected during August 2-5, 199 Observations and Findin s The spent fuel storage facilitywas inspected on August 4, 1999.
No deficiencies were noted.
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Conclusions Because the spent fuel storage facilitywas located within an existing Protected Area (PA) that met all regulatory requirements and was compliant with the NRC approved Physical Security Plan (the Plan), no additional security provisions for the spent fuel storage facilitywere required.
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~Trainin Ins ection Sco e 60854
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The inspectors reviewed the ISFSI training program, materials, and records.
The establishment of criteria to determine which individuals required training and the Certificate of Compliance (CoC) requirement that training should include an overview, radiological safety issues, off-normal event procedures, and licensing requirements were inspected.
Information was gathered through observation of activities, including the dry run activities, tours of the affected areas, discussions with cognizant personnel, and review and evaluation of procedures and documents.
Observations and Findin s Training was conducted in two broad categories; a one day overview for all persons associated or interested in the ISFSI program and a special one day course designed to give ISFSI operators handling the fuel, the DSC, the HSM or providing direct support to the ISFSI program specialized training in the equipment and procedures.
In some cases, the specialized program was further enforced by a hands-on simulation to demonstrate an ability to conduct the activities. Various program areas such as security, health physics, and operations were or had developed and conducted their own training programs.
The NRC team reviewed the licensee's written training program procedures and observed part of the overview training program. The training programs were conducted in accordance with 10 CFR Parts 50 and 72 license requirements.
Atthe time of the inspection, many ofthe personnel had not completed the training required by PP&L. The licensee planned to complete the training program either prior to the fuel handling operations or use part ofthe fuel handling operation to provide the necessary hands-on experience.
The movement of spent fuel from the fuel pool to the DSC is to be done by the crews that normally perform fuel moves and are prepared for this work under existing plant procedures.
Specifically, the ISFSI training materials for HP personnel covered the standardized NUHOMS design (overview), the ISFSI facilitydesign (overview), the CoC conditions (overview), the fuel loading, transfer cask handling, and DSC transfer procedures, and the off-normal event procedures.
Each of these topics was presented in detail, and the
b.
Observations and Findin s The CoC (Certificate No.1004, Standardized NUHOMS Horizontal Modular Storage System, Model No. NUHOMS-52B for Boiling Water Reactor Fuel) addressed heavy loads requirements.
The CoC required that lifts of the DSC in the transfer cask TC were to be made within the existing heavy loads requirements and procedures of the licensed nuclear power plant. The TC design was reviewed by the NRC in accordance with 10 CFR Part 72 and found to meet NUREG-0612 (Control of Heavy Loads at Nuclear Power Plants) and ANSI N14.6 (Special Lifting Devices for Shipping Containers Weighing 10,000 Pounds or More for Nuclear Materials). A licensee review of heavy loads requirements was documented in Safety Evaluation NL-96-055 and stated that all lifts would comply with NUREG-0612 and with SSES Heavy Loads Program requirements.
SSES had a heavy loads program as defined in NDAP-QA-0505 Crane, Hoist, and Rigging Program.
The program was further defined and implemented by procedures NDAP-QA-0505, NDAP-QA-0507, MT-GM-013, MT-GM-014, and MT-199-001. NDAP-QA-0505 addressed oversight of activities involving heavy loads greater than 1000 pounds, such as inspections for cranes, hoist, rigging, and liffingequipment, load testing requirements for cranes, hoist, rigging, and lifting equipment, quatification requirements for inspectors and crane operators, and compliance guidance to meet NUREG-0612 commitments.
NDAP-QA-0507, Conduct of Refuel Floor, addressed control of heavy loads with potential to impact fuel. MT-GM-013 Crane and Installed Hoist Mechanical Inspection controlled the periodic inspection of this equipment.
MT-GM-014 Rigging and Lifting Equipment Inspection controlled the inspections of rigging equipment used at Susquehanna SES.
MT-199-001 Reactor Building Crane Operating Procedure (1H213)
provided guidelines for operation of the Unit 1 crane.
These guidelines included checks and operating directions to ensure that the crane was maintained and operated as Single Failure Proof. Additionally, this procedure stated that, for this crane, a suspended load could remain suspended indefinitely, that time was to be taken as necessary to explore possible corrective actions in a suspended load emergency situation, and that emergency lowering of a suspended load, using manual brake release application described in this procedure, be performed only in those cases where failures render the hoist system useless and where all viable corrective means have been previously undertaken to repair the deficient condition.
tn preparation for the heavy loads involved with the ISFSI activities requiring a single-failure-proof crane, the licensee arranged for an independent assessment of the crane by American Crane and Equipment Corporation (ACECO). ACECO provided a report titled Single-Failure-Proof Certification/Inspection Analysis for the Unit 1 Reactor Building Crane and dated February 17, 1999. This report concluded that the heavy loads program and equipment were in good condition, listed minor problems and gave associated recommendations.
The licensee generated a Condition Report No. 90795 which listed each of the recommendations and required each to be evaluated for action.
The evaluations were conducted, and actions were taken to disposition all of the recommendations except for several which were categorized as not necessary to maintain the status ofthe crane as operable as single-failure-proo All new rigging w'as purchased for the ISFSI heavy loads activities. Calculation No. 16-77.0203, Susquehanna Rigging Requirements for Cask, DSC, and DSC Shield Plug Lifts, was performed to determine the specification requirements for the three applicable rigging assemblies.
Then the rigging was purchased for PPB L by Transnuclear West per the Specification for Rigging for Lifts of the Cask, DSC, and DSC Shield Plug for the Susquehanna NUHOMS System (No. 16-77-107), including yoke adapter, slings, shackles, turnbuckles, and hoist rings.
During dry run activities, lifts of the TC with a DSC, containing a mass which simulated a full load of fuel assemblies, were made from the Unit 1 reactor building railroad bay on elevation 670'o elevation 818'refuel floor) and along the safe load path on the refuel floor using the Unit 1 reactor building crane.
The rated capacity of this crane was" 125 tons, and the rated capacity of the NUHOMS transfer cask steel liftingyoke was 105 tons (210,000 pounds).
Typical heavy loads for this ISFSI system which required compliance with NUREG-0612 or equivalent included the following:
199,500 pounds 157,731 pounds 101,510 pounds 28,000 pounds 7,800 pounds 1,850 pounds 1,300 pounds 1,250 pounds transfer cask with loaded dry shielded canister transfer cask with unloaded dry shielded canister transfer cask (TC) without top cover installed and with neutron shield drained dry shielded canister (DSC) empty DSC shield plug welding head with cables and radiation shield DSC top cover strong back DSC outer top cover The Certificate of Compliance maximum handling height requirement for the loaded TC/DSC was incorporated into the appropriate ISFSI procedures.
Conclusions The Certificate of Compliance requirements for heavy loads and for maximum handling height for the loaded TC/DSC were adequately addressed based on appropriate procedures being in place, including procedures for qualification of crane operators, on the independently verified operable condition of the single-failure-proof crane, on the
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quality control measures on the ISFSI rigging, and on the documentation of the safe load path.
13.
Plannin for Off-Normal Events Ins ection Sco e 60854 Information on planning for off-normal events during the ISFSI process was gathered through observation of activities, including the dry run activities, tours of the affected areas, discussions with cognizant personnel, and review and evaluation of procedures and documents.
The inspectors reviewed applicable procedures and document b.
Observations and Findin s ON-081-001, Fuel Handling Accident, and ON-081-002, Refueling Platform Operation Anomaly, addressed off-normal events and were updated to include the DSC evolutions.
MT-199-001, Reactor Building Crane Operating Procedure (1H213), described actions to be taken in the case of an emergency suspended load situation.
RE-081-043, Selection and Monitoring of Fuel for Dry Storage, implemented monitoring the temperature rise across the horizontal storage modules and provided actions to be taken ifthe temperature rise was greater than expected.
The dry fuel storage implementing procedures, ME-ORF-141 thru -150, included general instructions for unusual occurrences or unforeseen circumstances requiring that shift supervision be notified immediately. Additionally, they required that items being moved be placed in a safe and stable condition (to prevent motion and maximize shielding) and that operations cease until appropriate plant management had evaluated the situation.
Conclusions The planning for off-normal events was reasonable and adequate based on the identified changes in the site emergency plan described in Section 9.0 of Report No. 99-08 and on the information provided in the new dry fuel storage procedures and the revised plant procedures.
14.
Exit Iteetln Summa The inspectors presented the inspection results to members of PP8L management at the conclusion ofthe inspection period, on September 2, 1999.
PP&L acknowledged the findings presented and had no comments.
The inspectors asked PP8L whether any materials examined during the inspection should be considered proprietary.
No proprietary information was identified
IP 37551 IP 60584 IP 60855 IP 71750 IP 81700 INSPECTION PROCEDURES USED Onsite Engineering Observations Preoperational Testing of an ISFSI Operation of an ISFSI Plant Support Activities Physical Security CFR CR EOP FSAR HPCI ISEG IR LER NCV NDAP NRC PORC PP&L SSES TS CFR CoC DCSS DSC HP HSM ISFSI NUHOMS QA RP SAR SER TC PARTIALLIST OF ACRONYMS USED Code of Federal Regulations Condition Report Emergency Operating Procedure Final Safety Analysis Report High Pressure Coolant Injection Independent Safety Engineering Group
[NRC] Inspection Report Licensee Event Report Non-Cited Violation Nuclear Department Administrative Procedure Nuclear Regulatory Commission Plant Operations Review Committee Pennsylvania Power and Light Company Susquehanna Steam Electric Station Technical Specification ACECO Code of Federal Regulations Certificate of Compliance (also C of C)
Dry Cask Storage System Dry Shielded Canister Health Physics Horizontal Storage Module Independent Spent Fuel Storage Installation Nuclear Horizontal Modular Storage (Technology)
Quality Assurance Radiation Protection Safety Analysis Report Safety Evaluation Report Transfer Cask
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