IR 05000395/2016009
| ML16120A470 | |
| Person / Time | |
|---|---|
| Site: | Summer, 07201038  |
| Issue date: | 04/28/2016 |
| From: | Sandra Walker Division of Nuclear Materials Safety II |
| To: | Lippard G South Carolina Electric & Gas Co |
| References | |
| IR 2016009 | |
| Download: ML16120A470 (27) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ril 28, 2016
SUBJECT:
VIRGIL C. SUMMER NUCLEAR STATION - NRC INDEPENDENT SPENT FUEL STORAGE INSTALLATION INSPECTION REPORT NOS. 05000395/2016009 AND 07201038/2016001
Dear Mr. Lippard:
On March 26, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Virgil C. Summer Nuclear Station and the NRC inspectors discussed the results of this inspection with Mr. George Lippard and other members of your staff on March 29 via a telephone exit meeting. Inspectors documented the results of this inspection in the enclosed inspection report.
This inspection involved a review of the preoperational demonstrations (the dry runs) and loading activities associated with the movement of spent fuel into the Independent Spent Fuel Storage Installation (ISFSI) as they relate to safety and compliance with the Commissions rules and regulations, and with the conditions of your license. The inspection covered many aspects associated with the preparation, movement, and placement of spent fuel into the ISFSI facility, and consisted of field observations, extensive examination of procedures and documents, and interviews with personnel. The inspectors reviewed dry run preparations and determined that they were thorough, and that individuals were appropriately trained and qualified in the performance of ISFSI-related tasks. The inspectors observed sound, conservative decision-making throughout the performance of the dry runs and the initial loading of spent fuel into the ISFSI facility.
The NRC inspectors did not identify any findings or violations of more than minor significance.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public inspections, exemptions, requests for withholding, of the NRC's "Rules of Practice," a copy of this letter, its Enclosure, and your response (if any), will be available electronically for public inspection in the NRCs Public Document Room, or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS),
which is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Shakur A. Walker, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-395 and 72-1038 License Nos. NPF-12
Enclosure:
IR 05000395/2016009 and 07201038/2016001 w/Attachment: Supplementary Information
REGION II==
Docket Nos: 50-395 and 72-1038 License Nos: NPF-12 Report Nos: 05000395/2016009 and 07201038/2016001 Licensee: South Carolina Electric & Gas (SCE&G) Company Facility: Virgil C. Summer Nuclear Station Location: P.O. Box 88 Jenkinsville, SC 29065 Dates: January 25, 2016 - March 26, 2016 Team Leader: Robert Carrion, Senior Reactor Inspector, Region II, Division of Reactor Safety (DRS), Engineering Branch 3 (EB3)
Inspectors:
Earl Love, Senior Transportation and Storage Safety Inspector, Office of Nuclear Materials Safety and Safeguards (NMSS), Division of Spent Fuel Management (SFM), Inspections & Operations Branch (IOB)
Jon Woodfield, Transportation and Storage Engineer, NMSS, SFM, IOB Zhian Li, Senior Criticality and Shielding Engineer, NMSS, SFM, Criticality, Shielding & Risk Assessment Branch (CSRAB)
Brendan Collins, Reactor Inspector, Region II, DRS, EB3 Jonathan Lizardi, Construction Inspector, RII, Division of Construction Inspection Approved by: Shakur A. Walker, Chief Engineering Branch 3 Division of Reactor Safety Enclosure
SUMMARY OF FINDINGS
IR 05000395/2016009 and 07201038/2016001; Virgil C. Summer Nuclear Station, spent fuel pre-loading demonstration and initial loading of spent fuel into the Independent Spent Fuel Storage Installation (ISFSI).
This report covers onsite inspection and in-office review by regional and Headquarters-based inspectors of activities related to the dry cask storage of spent fuel, including the preparation for loading of spent fuel from the spent fuel pool (SFP) to its placement at the ISFSI using the Holtec HI-STORM FW MPC Storage System. Upon completion of the dry run demonstrations on March 16, 2016, the licensee began activities to begin the transfer of spent fuel to the onsite ISFSI. The licensee successfully placed its first loaded HI-STORM FW on the ISFSI on March 26, 2016.
The inspectors reviewed the preoperational loading activities to confirm that personnel had been trained, equipment had been tested, and station programs and procedures had been developed, and were adequate to safely load spent fuel into the ISFSI. The inspectors also observed selected portions of the initial spent fuel transfer to the ISFSI to confirm that these activities were performed safely, in accordance with the approved procedures, the Certificate of Compliance (CoC), and Technical Specification (TS) requirements.
REPORT DETAILS
Summary of Facility Activities The South Carolina Electric & Gas (SCE&G) Company selected the Holtec International Storage Module (HI-STORM) Flood/Wind (FW) Multi-Purpose Canister (MPC) Storage System for storage of spent fuel at Unit 1 of the Virgil C. Summer Nuclear Station ISFSI. The HI-STORM FW MPC Storage System has been reviewed and approved by the Nuclear Regulatory Commission (NRC) and Certificate of Compliance (CoC) number 1032 issued, in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 72.238, to Holtec International (i.e., the CoC holder). The HI-STORM FW MPC Storage System, CoC 1032, is included in the list of NRC-approved casks provided in 10 CFR 72.214, and is therefore acceptable for use in accordance with the general license provisions of Part 72, Subpart K.
SCE&G elected to use Amendment 0 to the CoC, which became effective on June 13, 2011.
Demonstrations of loading, processing, and moving spent fuel from the SFP to the ISFSI, using the Holtec system, were conducted from January 26, 2016 to March 16, 2016, for the NRC.
During this period, the inspectors performed an evaluation to determine if the ISFSI personnel had been trained, the equipment had been tested, and the procedures had been developed to the extent necessary to safely load spent fuel into dry storage at the sites ISFSI. During the period from March 21 - 26, 2016, NRC inspectors observed activities associated with the initial loading of spent fuel into dry storage to ensure that those activities were performed safely, in accordance with approved procedures, within the technical specifications (TS) limits, and to determine if the SCE&G programs were adequate for continued operation, and maintenance of the ISFSI once the ISFSI was loaded.
4OA5 Other Activities
.1 V. C. Summer Nuclear Station Independent Spent Fuel Storage Installation Activities
.1.1 Preoperational Test Program
a. Inspection Scope
The CoC for the Holtec system for the storage of irradiated fuel requires the licensee to conduct preoperational testing to demonstrate the loading, closure, and transfer of the cask system prior to the first loading of spent fuel assemblies. The NRC conducted an onsite inspection to observe the licensees demonstration of the required activities. The inspection consisted of field observations, interviews with licensee personnel, and review of licensee documentation.
Per CoC No.1032, Condition 9, Preoperational Testing and Training Exercise, A dry run training exercise of the loading, closure, handling, unloading, and transfer of the HI-STORM FW MPC Storage System shall be conducted by the licensee prior to the first use of the system to load spent fuel assemblies. The training exercise shall not be conducted with spent fuel in the multi-purpose canister (MPC). The dry run may be performed in an alternate step sequence from the actual procedures, but all steps must be performed.
From January 26 - March 16, 2016, the inspectors observed several dry run activities.
Specifically, welding demonstrations were observed during the last week of January.
MPC fluid operations and cask drying operations, including de-watering, forced helium dehydration, and helium backfilling were observed February 9-12. From March 1-3, the inspectors observed dry operations, including transporting the HI-TRAC VW (Variable Weight), from the decon pit (DCP) to the stack up position on top of the HI-STORM FW; transferring the MPC with a dummy load of the same weight as the actual load into and out of the HI-STORM FW from/to the HI-TRAC VW; placing the lid on the HI-STORM FW; and moving the low profile transporter (LPT) bearing the loaded HI-STORM FW outside of the Fuel Building where the HI-STORM FW was transferred to the Vertical Cask Transporter (VCT) and transported along the designated heavy haul path to the ISFSI pad. From March 15-16, the inspectors observed wet operations, including transferring the HI-TRAC VW containing the MPC from the DCP into the cask loading pit (CLP) simulate the loading of the MPC with spent fuel using a dummy fuel assembly (including independent verification), and transporting the loaded HI-TRAC VW out of the CLP to the DCP where the welding, de-watering, drying and helium backfilling operations take place. Additionally, health physics technicians decontaminated and surveyed the HI-TRAC VW for unexpected dose rates. The inspectors noted that all activities were done in conjunction with draft ISFSI procedures developed by SCE&G.
Minor revisions to the procedures were approved and incorporated prior to the initial movement of spent fuel.
The licensee conducted a pre-job briefing each day, prior to the days demonstration, with personnel involved with the dry run activities. The briefings were comprehensive and effectively covered all key aspects of the evolution, including: procedural adherence expectations, safety aspects of the activities, and Quality Assurance (QA) hold points.
The inspectors noted that procedure compliance was adhered to during the performance of the activities. Radiological conditions were simulated and appropriate measures were implemented to provide a degree of realism, including simulated radiological postings to prepare workers for the radiological conditions that could be encountered during the actual transfer of active spent fuel. The inspectors interviewed cognizant personnel to verify their knowledge of procedural requirements and responsibilities. The inspectors also noted that activities were performed in a deliberate, methodical manner. The responsible supervisor maintained the work package/procedure in his possession throughout the performance of the activity, and procedural steps were carefully followed.
The licensee demonstrated the capability to safely place the MPC into the HI-TRAC VW.
Rigging, movement, and placement of the MPC into the HI-TRAC VW, and subsequently into the HI-STORM FW, were performed in a controlled manner with effective coordination and communication observed among individuals involved in the activity.
Throughout the entire dry run exercise, the work package was periodically reviewed by the inspectors to verify compliance with procedures and related work documents. The inspectors noted that procedure steps were circled and slashed, or otherwise notated, by the responsible supervisor to signify initiation and completion, respectively, of a given step and that work order documents were followed.
The ISFSI project personnel were qualified to perform their assigned functions and were knowledgeable of their responsibilities. Procedures and work-related documentation were accurate and procedural compliance was demonstrated by workers in the field.
b. Findings
No findings were identified.
.1.2 Control of Heavy Loads
a. Inspection Scope
The licensee had modified the existing crane in the Fuel Handing Building so that it was single-failure proof; it was certified and documented by the manufacturer to conform to the requirements of NUREG-0612 and NUREG-0554. The crane had been inspected in October 2014 by NRC inspectors in preparation for use in the dry cask storage project (NRC Inspection Reports 05000395/2014009 and 07201038/2014002 (Agencywide Document Accession Management System (ADAMS) Accession No. ML14325A539).
The inspectors reviewed work orders associated with maintenance of the crane since October 2014 to ensure that the crane, hooks, and wire rope were inspected, tested, and maintained in accordance with the ASME Code, NUREG-0554, NUREG-0612, and the crane manufacturers recommendations. The inspectors observed the licensee perform movements of heavy loads inside of the fuel handling building in the course of the dry runs and initial loading campaign, and noted appropriate supervisory oversight and radiological protection practices.
b. Findings
No findings were identified.
.1.3 Welding
a. Inspection Scope
The NRC inspectors observed and evaluated the performance of the welders and associated nondestructive examination (NDE) personnel contracted to perform the welding operations on the MPC to determine if they were qualified and working to approved procedures. The inspectors observed the welding equipment setup and welding on a mockup. The majority of the welding was done with an Automated Welding System (AWS) using the gas shielded arc welding (GTAW) process on the cask mockup lid-to-shell weld. The use of manual GTAW welding was also discussed and demonstrated on the drain/vent port cover plates. A visual examination (VT-1) and dye penetrant testing (PT) on the welds was observed by the inspectors and the inspectors compared the welding and NDE procedures to their respective work practices for compliance to applicable codes and standards. The inspectors also reviewed welding procedure documentation, welder performance qualifications, and NDE procedures and NDE personnel qualifications to verify that the respective Code and procedural requirements were met.
During the initial loading campaign, the inspectors observed preparations for welding the lid of the MPC and noted that contractor personnel were knowledgeable of their work activities and worked closely with licensee personnel. Rigging and handling of the shield bell, welding machine, and associated equipment were performed in a safe manner during the processing of the first MPC. The individuals were knowledgeable of procedural requirements and followed approved rigging and lifting practices.
The inspectors concluded that the capability to adequately weld and perform NDE on MPCs was sufficiently demonstrated on the mockup and further verified during the first loading campaign; and that personnel were qualified to perform their assigned functions.
b. Findings
No findings were identified.
.1.4 Review of Evaluations
a. Inspection Scope
(Inspection Procedures 60856 and 60857)
A general license for the storage of spent fuel in an ISFSI at power reactor sites is granted per 10 CFR 72.210, General license issued. Per 10 CFR 72.212, Conditions of general licenses issued under 72.210, the holder of the general license is required to perform written evaluations prior to use (specifically under 72.212(b)(5)) to establish that the ISFSI design can be used at that site, and that site operations can accommodate operation of an ISFSI. SCE&G holds a general license for operation of its ISFSI.
SCE&G documented the results of the required evaluations in VCS Unit 1 10 CFR 72.212 Evaluation Report, Revision 0. The inspectors reviewed the technical report and various referenced supporting documents to evaluate the licensees compliance with the requirements of 10 CFR 72.212. The inspectors also conducted interviews with cognizant licensee personnel.
10 CFR 72.212 Report The inspectors reviewed a copy of the SCE&G draft VCS Unit 1 10 CFR 72.212 Evaluation Report, Revision 0, during the team inspection from March 1-3, 2016. The final approved report was made available to the inspectors just prior to the initial loading campaign. Based on the review, the inspectors assessed that, overall, the report was comprehensive and adequately addressed the areas required to be evaluated under 10 CFR 72.212(b)(1) through (8), and
- (10) through (14). The 10 CFR 72.212 evaluation report was found to be acceptable; it contained sufficient objective evidence that the written evaluations confirmed that the conditions set forth in the CoC had been met, the ISFSI pad had been designed to support the stored load of the casks, and the requirements of 10 CFR 72.104 had been met for the radiological impact to members of the public.
Fire and Explosion Analysis of Hauling and Storage The inspectors reviewed the supporting documents referenced in the 10 CFR 72.212 evaluation report, including the fire hazards analysis for the VCT, the fire hazards analysis for spatial separation requirements for combustion sources for V. C. Summer Nuclear Station ISFSI, and the evaluation of the thermal effects of the combustion of onsite gasoline and diesel fuel storage tanks on spent fuel transport to, and storage at, the ISFSI. The inspectors verified that the calculations and analysis had been completed, including the specifications of the Virgil C. Summer Nuclear Station ISFSI and HI-STORM FW MPC Storage System, and contained conservative assumptions; and identified any required operational restrictions based on the results of the calculations. The inspectors reviewed the calculation and analysis documents and did not identify any concerns that would contradict the conclusion made by SCE&G.
HI-STORM FW MPC and Independent Spent Fuel Storage Installation Dose Limits Title 10 CFR 72.104, Criteria for radioactive materials in effluents and direct radiation from an ISFSI or Monitored Retrievable Storage Installation (MSRI), require that the annual dose equivalent to any real individual, located beyond the controlled area, must not exceed 25 millirem (mrem) to the whole body, 75 mrem to the thyroid, and 25 mrem to any other critical organ, as a result of exposure to direct radiation from ISFSI operations. Section 5.3 of the 10 CFR 72.212 report provided the evaluation of meeting the dose requirements of 10 CFR 72.104. The V. C. Summer Nuclear Station ISFSI pad is located within the plants protected area, with a minimum distance to the nearest owner-controlled boundary of approximately one mile (1,600 meters). The ISFSI will contain a maximum of 98 HI-STORM FW MPC-37 canisters. The report described the results of calculations that show the annual offsite dose contribution from direct radiation, to the closest (at 1760 meters) permanent resident due to the ISFSI to be 0.0135 mrem. The estimated annual dose due to power generation at VCSNS Units 1, (as well as 2 and 3 when operation begins) is less than 2 mrem. Therefore, the total annual dose to the closest real individual is within the 10 CFR 72.104(a) limit of 25 mrem.
Independent Spent Fuel Storage Installation Pad Parameters In accordance with 10 CFR 72.212(b)(5)(ii), SCE&G is required to make a finding that the ISFSI pad and area can support the static and dynamic loads of the number of fully loaded HI-STORM FW MPC Storage Systems that will be placed on its ISFSI pad, considering the amplification of earthquakes through soil structure interaction, and soil liquefaction potential or other soil instability due to vibratory ground motion. Section 5.2 of the SCE&G 72.212 report contained a summary of the analysis performed by Holtec International for SCE&G.
The SCE&G ISFSI storage pad is designed to adequately support both static and dynamic loads of 98 loaded Holtec HI-STORM FW MPC Storage Systems. The ISFSI pad design meets the requirements of 10 CFR Part 72, the HI-STORM FW Final Safety Analysis Report (FSAR), and CoC No. 1032. Therefore, the requirements of 10 CFR 72.212(b)(5)(ii) are met.
Site-Specific Parameters Title 10 CFR 72.212(b)(6) requires general licensees to review the Safety Analysis Report (SAR) referenced in the CoC, and the related NRC Safety Evaluation Report (SER), prior to use of the general license to determine whether or not the reactor site parameters (including analyses of ambient temperature and temperature extremes, flooding, effects of tornados, earthquake intensity and seismic acceleration, lightning, snow and ice loads, and burial under debris) are enveloped by the cask design bases considered in these reports.
The inspectors determined that the licensee performed a review, documented in the 10 CFR 72.212 report, of the reactor site parameters that are evaluated in the certification of the design of the HI-STORM FW MPC Storage System, to ensure compliance with the requirements of 10 CFR 72, Subpart K, General License for Storage of Spent Fuel at Power Reactor Sites. The inspectors determined that the applicable reactor site parameters were evaluated for acceptability with the bounding values specified in the HI-STORM FW MPC SAR, and the NRC SER. The evaluations demonstrated that the design features for the HI-STORM FW MPC Storage System either enveloped the site-specific characteristics of the V. C. Summer site or enveloped the site-specific characteristics of the SCE&G with administrative controls on the implementation of the HI-STORM FW MPC Storage System (e.g., limiting use of the HI-TRAC VW to working area ambient temperatures greater than or equal to 0ºF).
Conformance to the Conditions of the Certificate of Compliance Title 10 CFR 72.212(b)(5)(i) requires the general licensee to perform written evaluations, before use, which establish that the cask, once loaded with spent fuel, will conform to the terms, conditions, and specifications of a CoC. The inspectors reviewed how SCE&G complied with the conditions of the CoC for preoperational testing and training exercise of the HI-STORM FW MPC Storage System at SCE&G. Appendix 1 of the SCE&G 72.212 report, entitled HI-STORM FW MPC Storage System Certificate of Compliance Evaluation, contains a tabulation of the applicable conditions for the HI-STORM FW MPC Storage System and SCE&G. The inspectors reviewed the implementation of several of these conditions at SCE&G and verified that they had been performed, or were captured, in the procedures established for the HI-STORM FW MPC loading at SCE&G.
10 CFR 72.48 Screening and Evaluation Holtec is authorized by 10 CFR 72.48 to make changes to the NRC-approved CoC for the HI-STORM FW MPC Storage System, provided that those changes are reviewed to determine if the changes would hinder or prevent a structure, system, or component (SSC) of the HI-STORM FW MPC Storage System to perform its design function as described in the HI-STORM FW MPC FSAR. Holtec has made changes to the HI-STORM FW MPC FSAR using this authority and has screened them for impacts to the SSCs. The inspectors verified that SCE&G also reviewed these changes for impacts to the SSCs and agreed that none of the changes required prior NRC approval (i.e., a CoC amendment).
Likewise, SCE&G is granted authority to make changes to the HI-STORM FW MPC system design, or FSAR description, in accordance with the provisions of 10 CFR 72.48.
The site-specific changes made to the HI-STORM FW MPC Storage System by SCE&G were identified in the 72.212 report. The inspectors verified that these changes were screened using the SCE&G 72.48 screening process, concluding that none of the changes adversely impacted the HI-STORM FW MPC SSCs.
10 CFR 50.59 Screening and Evaluation Movement of the loaded HI-STORM FW MPC Storage System from the Fuel Handling Building to its designated storage position in the ISFSI was evaluated by SCE&G to determine the potential for this activity to impact Part 50 reactor SSCs which are important to safety. The licensee designed the heavy haul path to support the weight of the VCT to carry a loaded HI-STORM FW MPC Storage System. Underground conveyances were either relocated or analyzed, to provide assurance that reactor SSCs considered important to safety would continue to perform their intended safety function, as described in the SCE&G FSAR. Additionally, SCE&G restricted movement of the VCT to the heavy haul path. The inspectors confirmed that the operation of the ISFSI, and associated changes to the Part 50 facility, were reviewed by the licensee in accordance with the provisions of 10 CFR 50.59(c), and a determination made that they do not involve a change to the facilitys TS, or a license amendment, pursuant to 10 CFR 50.90. Therefore, the licensee determined that prior NRC approval, in the form of a license amendment or change to the TS, was not required. Accordingly, the licensee determined that it was in compliance with the requirements of 10 CFR 72.212(b)(8) for operation of the SCE&G ISFSI in accordance with the general license provisions of 10 CFR Part 72, Subpart K.
b. Findings
No findings were identified.
.1.5 Quality Assurance Program (QAP)
a. Inspection Scope
Per CoC No. 1032, Condition 3, Quality Assurance (QA), activities at the ISFSI shall be conducted in accordance with a Commission-approved QAP that satisfies the applicable requirements of 10 CFR Part 72, Subpart G, Quality Assurance, and which is established, maintained, and executed with regard to the storage system. The provisions of 10 CFR 72.140(d), Previously-approved programs, accept a QAP previously approved by the Commission which satisfies the requirements of Appendix B to Part 50. The inspectors noted that the licensee had provided the required notification to the NRC of its intent to apply its previously-approved 10 CFR 50, Appendix B, Quality Assurance Program, to its ISFSI activities.
The involvement and role of QA was evaluated to ensure that sufficient independence was established to verify that the ISFSI program was effectively developed and implemented to support the safe operation of the ISFSI facility. The use of the condition reporting program in support of ISFSI activities was also evaluated. The inspection consisted of field observations, interviews with licensee personnel, and review of licensee documentation. The inspectors reviewed applicable sections of the licensees QAP, procedures, and documentation related to nonconformance items, corrective actions, control of measuring and test equipment, handling and storage controls, and procurement control to verify adequate implementation of the licensees QAP for the ISFSI activities.
The inspectors reviewed licensee self-assessments, QA observations, and baselining trip reports. The inspectors noted that these documents were self-critical and identified various issues to be addressed in support of ISFSI operational readiness. The inspectors noted that audit findings were entered into the licensees corrective action program.
The inspectors reviewed a sample of the licensees condition and nonconformance reports to verify that the licensee was adequately implementing its 10 CFR Part 50 corrective action program as it pertained to the ISFSI program and related activities.
The inspectors reviewed the corrective actions related to issues concerning ISFSI activities to verify that resolution was appropriate, the issue was properly documented, and that appropriate levels of management were notified. The inspectors noted that ISFSI-related issues were identified at a low safety threshold, and corrective actions implemented in a timely manner.
The inspectors noted that QA personnel attended the dry run briefings and were actively engaged in field activities, and verified that hold points, technical specifications, and work order requirements were implemented in accordance with approved procedures and related work documents. Calibration records for selected instruments were reviewed to verify that calibrations were current.
The inspectors reviewed the QAP to determine whether the licensee had any material or equipment that required special handling or storage and, if so, that adequate procedures and controls were in place. The licensee had established controls for procurement and receipt of items. The inspectors reviewed t h e Quality Plan for the Receipt of Holtec Major Components and Ancillary Devices Associated with Dry Cask Storage, Revision 1, and ES-361; Receipt Inspection, Revision 12, which incorporated applicable requirements from the FSAR. The inspectors verified that QAP-classified equipment, structures, systems and components were identified in the appropriate safety class in accordance with FSAR requirements. A number of licensee documents, including drawings, and receipt and procurement documentation, was reviewed to determine if the safety classification of items important-to-safety was adequately translated and specified in those documents. The inspectors also observed the HI-STORM FW storage overpacks to be used for future loading to verify that there were no apparent structural indications, such as visible cracks, on their walls or damage to screen plates on the vents.
b. Findings
No findings were identified.
.1.6 Procedures and Technical Specifications
a. Inspection Scope
The CoC for the Holtec HI-STORM FW MPC Storage System, in conjunction with the associated TSs (Appendix A to CoC No. 1032, Amendment 0), specifies requirements to ensure the safe handling and storage of spent nuclear fuel. The inspectors confirmed that copies of the CoC and referenced documents were current.
The inspectors reviewed a series of licensee procedures and documentation to confirm that the TS requirements were incorporated into ISFSI work-related documents and work packages. The licensee developed procedures to address:
- Preparing the HI-TRAC VW / MPC to receive spent fuel assemblies,
- Placing the MPC into the HI-TRAC VW,
- Drying, and helium backfilling,
The procedures were comprehensive and adequately addressed key aspects of the evolutions. The procedures contained sufficient detail to support safe handling and movement of the MPC, HI-TRAC VW, and HI-STORM FW MPC storage overpack. The inspectors noted that the procedures covered all aspects of dry spent fuel handling, loading, and storage requirements, as required by the TSs. The inspectors also verified that there were adequate procedures to monitor the thermal performance of the HI-STORM FW MPC Storage Systems.
b. Findings
No findings were identified.
.1.7 Training and Qualifications
a. Inspection Scope
The licensees training program was reviewed to verify that appropriate training requirements were identified for ISFSI-related tasks, and that personnel were qualified to perform ISFSI-related activities. The licensees training program was also reviewed to verify that the required elements described in 10 CFR 72, Subpart I, Training and Certification of Personnel, and CoC No. 1032, Amendment 0, Condition 9, Pre-Operational Testing and Training Exercise, were incorporated into the ISFSI training program to ensure the safe handling and storage of spent nuclear fuel. The inspection consisted of a review of licensee documentation and interviews with cognizant personnel. The NRC inspectors confirmed that copies of CoC, Amendment 0, and referenced documents were current.
The inspectors interviewed training personnel regarding the training and qualification of personnel performing ISFSI-related activities. Overview training was provided by the licensee to personnel with ISFSI-related responsibilities. Several training modules were specifically developed for the ISFSI activities, including a general overview of the ISFSI project and job/task-specific modules that covered activities such as preparation and loading of the MPC, design and licensing basis, licensing Part 72, and off-normal conditions.
The inspectors noted that activities such as forced helium dehydration, helium backfilling, and welding of the MPC lid were to be performed by qualified contractor personnel with previous experience in these task areas. Based on discussions with licensee personnel, the inspectors verified that the licensee had evaluated the training and qualification of contractor personnel to perform their intended functions.
The inspectors reviewed selected training modules and noted that they were comprehensive and adequately covered training aspects of a given task. The inspectors noted that the licensee designated individuals as qualified to perform a given task based upon successful completion of the required training modules.
Based on field observations and discussions with personnel during initial cask loading activities, the inspectors concluded that the individuals conducting ISFSI activities were properly trained and qualified to perform their assigned functions.
b. Findings
No findings were identified.
.1.8 Radiation Protection
a. Inspection Scope
The licensees radiation protection program was evaluated to verify that the elements of 10 CFR 72.126, Criteria for radiological protection, had been incorporated into procedures for ISFSI-related tasks and that they were effectively implemented by licensee personnel. Compliance with 10 CFR 72.104, Criteria for radioactive materials in effluents and direct radiation from an ISFSI or MPC, and 10 CFR 72.106, Controlled area of an ISFSI or MPC, was reviewed. The inspectors evaluated the effectiveness of the licensees plans and preparations for controlling radiological activities by direct observation, by reviewing documents, and interviewing individuals with radiation protection responsibilities.
The inspectors reviewed the licensees radiation protection program, including documents associated with the operating procedures of the ISFSI, the radiation protection program of the loading campaign, and radiation protection program for the controlled area boundary of the ISFSI.
The inspectors reviewed the licensees As Low As is Reasonably Achievable (ALARA)work plan and dose estimate for loading the first Holtec MPC. Based on discussions with licensee personnel and a review of documentation, the inspectors determined that an appropriate dose goal had been established for the first Holtec cask loading. The inspectors noted that the dose estimate for the initial cask loading was in reasonable agreement with estimated dose values noted in the Holtec FSAR. The ALARA work plan adequately addressed the use of temporary shielding at key steps of the evolution, and that adequate contamination control and dose reduction measures were incorporated into the ALARA work plan. The inspectors noted that applicable procedures specified the need to perform radiological surveys at critical steps of the loading sequence, and when handling and transporting the loaded canister. Verification steps were incorporated into approved procedures to ensure that dose rates and contamination levels were in compliance with applicable limits specified by the TSs.
b. Findings
No findings were identified.
.1.9 Fuel Characterization and Verification
a. Inspection Scope
The CoC for the Holtec dry cask storage system specified the parameters that must be met in order to allow spent fuel to be stored at the ISFSI. The inspectors evaluated licensee programs to verify that spent fuel assemblies selected for storage met the applicable requirements of the CoC. The inspection consisted of interviews with licensee personnel and review of documentation.
The inspectors reviewed the licensees process for selecting and verifying fuel assemblies for placement in the MPC. The inspectors reviewed documents associated with the qualification, characterization, and selection of fuel assemblies for storage at the ISFSI. Technical Specifications require that selected fuel assemblies be visually inspected, independently identified, be free of cladding defects, and be within specified limits for such parameters as fuel enrichment, burn-up, and decay heat output. The inspectors discussed the fuel selection process with licensee personnel and determined that individuals were knowledgeable of the TS requirements. The inspectors reviewed documentation of visual fuel examinations performed for the 37 fuel assemblies to be loaded into the MPC, which was subsequently loaded into the HI-STORM FW MPC overpack and placed on the ISFSI pad to verify that the examinations were performed in accordance with approved procedures.
Examinations were performed in accordance with approved procedures. The inspectors noted that the selected fuel assemblies met all the appropriate TS requirements for placement into a MPC for dry storage. Supporting documentation adequately characterized the selected fuel assemblies for loading into a MPC.
The licensee had developed a cask loading plan in accordance with approved procedures. Licensee documentation supported the proper characterization of fuel assemblies to be loaded into a Holtec MPC, and was in compliance with design parameters specified in the CoC.
b. Findings
No findings were identified.
.1.10 Records
a. Inspection Scope
Title 10 CFR 72.72 requires that a licensee keep records showing the receipt, inventory (including location), disposal, acquisition, and transfer of all special nuclear material (SNM). In addition, 10 CFR 72.212(b) requires that a licensee maintain a copy of the CoC, and documents referenced therein, for each cask model used for storage of spent fuel, until use of the cask model is discontinued, and that a copy of the 10 CFR 72.212 Evaluation Report shall be retained until spent fuel is no longer stored under the general license issued under 10 CFR 72.210.
Additional general license requirements dealing with the review of the reactor emergency plan, quality assurance program, training program, and radiation protection program must also be satisfied pursuant to 10 CFR 72.212(b)(10). Records and procedural requirements for the general license holder are described in 10 CFR 72.212(b)(11), (12), (13), and (14).
The licensee had established records for SNM accountability. The inspectors reviewed procedures REP-100.003, Special Nuclear Material Physical Inventory, REP-100.004, Special Nuclear Material Reporting, and REP-100, Special Nuclear Material Physical Inventory Program Administration and Organization, which tracked the locations at which the fuel assemblies are stored in the SFP. The inspectors observed that the licensee had initiated Condition Report (CR) 16-00453 to track the development and submittal of a site-specific decommissioning plan to the NRC in accordance with 10 CFR 70.30(a).
The inspectors also reviewed procedure HPP-2036-200, MPC-37 Loading at VC Summer, which outlined the steps for identifying the fuel assemblies to be loaded, placing the fuel assemblies into the MPC, and verifying that the MPC had been correctly loaded. The inspectors reviewed a copy of the CoC and its referenced documents (i.e., TSs, FSAR, and the NRC SER) to verify that these documents were maintained in accordance with 10 CFR 72.212(b)(11). The inspectors noted that the licensee had made the required 90-day notification to the NRC prior to loading their first cask on the ISFSI, and had established procedural requirements to register each cask with the NRC within 30 days after loading, per procedure SAP-1410, Dry Fuel Storage Program Manual.
The inspectors reviewed selected referenced records and procedure changes related to the emergency preparedness, fire protection, training, health physics, and quality assurance programs to determine if their effectiveness had been Impacted by ISFSI activities. The inspectors interviewed cognizant personnel to confirm that they were knowledgeable of the impact of ISFSI-related activities. For instance, the inspectors interviewed Emergency Preparedness management, with respect to coordination with offsite organizations that may be called upon to respond during a major fire at the plant.
b. Findings
No findings were identified.
.1.11 Initial Loading of the MPC/HI-STORM FW
a. Inspection Scope
From March 21-26, the inspectors observed activities associated with moving spent fuel from wet storage in the spent fuel pool to dry storage on the ISFSI pad. The previously performed Dry Runs had proven to be an effective representation of the actual activities and no significant differences were noted by the inspectors and no significant issues were encountered by the licensee during the evolution. The inspectors noted that all activities were done in accordance with approved ISFSI procedures developed by SCE&G and that minor revisions to the procedures as a result of observations made during the Dry Runs had been incorporated prior to the initial movement of spent fuel.
The licensee conducted a pre-job briefing prior to each shift with personnel involved with the shifts loading activities. The briefings were comprehensive and effectively covered all key aspects of the evolution, including procedural adherence expectations, safety aspects of the activities, and QA hold points. The inspectors noted that procedure compliance was adhered to during the performance of the loading activities.
Radiological conditions were constantly monitored to ensure the safety of personnel working on the loading activities. The responsible supervisor maintained the work package/procedure in his possession throughout the performance of the evolution, and procedural steps were carefully followed. Throughout the loading evolution, the work package was periodically reviewed by the inspectors to verify compliance with procedures and related work documents. The inspectors noted that procedure steps were circled and slashed, or otherwise notated, by the responsible supervisor to signify initiation and completion, respectively, of a given step and that work order documents were followed, just as had been done during the Dry Runs. The presence of licensee supervision was noted during the loading activities.
b. Findings
No findings were identified.
4OA6 Meetings
.1 Exit Meeting Summary
The results of the inspection were discussed at an exit meeting conducted on March 29, 2016, via telephone with Mr. George Lippard, V. C. Summer Nuclear Station Site Vice President of Nuclear Operations, and other members of the staff.
ATTACHMENT: Supplementary Information
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- D. Bryon, Reactor Engineering Engineer
- B. Dalick, Nuclear Licensing Engineer
- T. Ellison, Project Lead for Dry Storage
- J. Harrington, Project Manager
- W. Herwig, Reactor Engineering Supervisor
- G. Lippard, V. C. Summer Nuclear Station Site Vice President of Nuclear Operations
- M. Moore, Nuclear Licensing
- R. Russell, Design Engineering
B. Thompson Nuclear Licensing Manager
- J. Thompson, Health Physics Supervisor
- R. Williamson, Emergency Protection Manager
- S. Zarandi, General Manager, Nuclear Support Services
Holtec International
- J. Sloan, Dry Cask Storage Operations Supervisor
- L. Johnson, Dry Cask Storage Operations Supervisor
NRC
J. Reece - V. C. Summer Senior Resident Inspector
- E. Coffman, - V. C. Summer Resident Inspector
LIST OF REPORT ITEMS
Opened and Closed
None.