IR 05000440/2011010
| ML110700566 | |
| Person / Time | |
|---|---|
| Site: | Perry, 07200069  |
| Issue date: | 03/11/2011 |
| From: | Christine Lipa Division of Nuclear Materials Safety III |
| To: | Bezilla M FirstEnergy Nuclear Operating Co |
| References | |
| IR-11-002, IR-11-010 | |
| Download: ML110700566 (25) | |
Text
March 11, 2011
SUBJECT:
NRC INSPECTION REPORT NUMBERS 072-00069/11-002(DNMS);
050-00440/11-010 - DRY FUEL STORAGE STACK-UP OPERATIONS AT THE PERRY NUCLEAR POWER PLANT
Dear Mr. Bezilla:
On March 4, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed its inspection of the proposed inter-cask transfer operation, known as stack-up, at the Perry Nuclear Power Plant. The purpose of the inspection was to determine whether the freestanding stack-up configuration is permissible by the applicable licensing basis. An exit teleconference was held on March 4, 2011, where the inspectors discussed the preliminary inspection findings with Mr. V. Veglia and other members of your staff. The enclosed report documents the inspection results.
During this inspection, the NRC staff examined design documents performed under your license as they relate to public health and safety. Specifically, the inspectors reviewed stability calculations and evaluations for the proposed inter-cask transfer operation. Details of the documents reviewed are identified in the enclosed report. The inspection also consisted of dialogue between the NRC staff and your personnel.
The inspection was conducted per NRC Inspection Manual 2690, Inspection Program for Dry Storage of Spent Reactor Fuel at Independent Spent Fuel Storage Installations and Guidance for Title 10 of the Code of Federal Regulations (CFR) Part 71 Transportation Packages, and used portions of Inspection Procedure (IP) 60854.1, Preoperational Testing of an ISFSI at Operating Plants. This report details the results of the inspection related to stack-up only. The remaining inspection performed under IP 60854.1 is ongoing and will be documented in a future inspection report.
Based on the results of this inspection, the NRC has determined that the proposed freestanding stack-up configuration is not in accordance with the licensing basis and one Severity Level IV violation of NRC requirements was identified. This violation is being treated as a Non-Cited Violation (NCV), consistent with Section 2.3.2 of the enforcement policy, and is discussed in the enclosed inspection report. If you contest the subject or severity of this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Perry Nuclear Power Plant.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response (if any), will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/readingrm/adams.html.
Sincerely,
/RA/
Christine A. Lipa, Chief Materials Control, ISFSI, and Decommissioning Branch Division of Nuclear Materials Safety
Docket Nos.: 72-069 and 50-440 License No.: NPF-58
Enclosure:
NRC Inspection Reports 072-00069/11-002(DNMS)
and 050-00440/11-010
REGION III==
Docket Nos.72-069; 50-440
License No.
Report Nos.
072-00069/11-002(DNMS);
050-00440/11-010
Licensee:
FirstEnergy Nuclear Operating Company
Facility:
Perry Nuclear Power Plant, Unit 1
Location:
Perry, OH
Inspection Dates:
July 26, 2010 - March 4, 2011
Inspectors:
Rhex Edwards, Reactor Inspector
Matt Learn, Reactor Engineer
Jim Neurauter, Senior Reactor Inspector
Approved by:
Christine A. Lipa, Chief
Materials Control, ISFSI,
and Decommissioning Branch
Division of Nuclear Materials Safety
EXECUTIVE SUMMARY
Perry Nuclear Power Plant, Unit 1 NRC Inspection Report Nos. 072-00069/11-002(DNMS); 050-00440/11-010
The purpose of the inspection was to evaluate the licensees proposed activities associated with the inter-cask transfer conducted during dry fuel storage operations. During this inspection, region based inspectors were unable to draw conclusions from available guidance and sought the expertise of the U.S. Nuclear Regulatory Commission (NRC), Office of Nuclear Material Safety and Safeguards (NMSS), through a Technical Assistance Request (TAR). This guidance is included as Attachment 2 to this inspection report. The breadth of this inspection report is limited and only details the results of the inspection related to inter-cask transfer operations.
The remaining inspection performed under IP 60854.1 is ongoing and will be documented in a future inspection report.
Dry Fuel Storage Transfer Activities:
- The NRC staff determined that the proposed inter-cask transfer activities do not meet the current licensing basis and that the proposed evolution would require: a lateral restraint system; an exemption to not use lateral restraints; or a request from the certificate holder for a Certificate of Compliance (CoC) amendment.
- The inspectors identified one Severity Level IV Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (CFR) 72.146, Design Control.
Report Details
1.0 Preoperational Testing of an Independent Spent Fuel Storage Facility (ISFSI) at Operating Plants (60854.1)
a.
Inspection Scope
The scope of Inspection Procedure (IP) 60854.1 includes verifying that loading, unloading, and transfer activities meet the commitments and requirements specified in the Dry Cask Storage System Safety Analysis Report (SAR), Safety Evaluation Report (SER), Certificate of Compliance (CoC), and Title 10 of the Code of Federal Regulations (CFR) Part 72. Additionally, the inspection procedure has the inspectors verify that the equipment used during preoperational test activities has been tested and/or evaluated for its impact on plant structures, systems and components before performance of the preoperational tests. From this inspection guidance, the NRC inspectors conducted a review of Perry Nuclear Power Plants proposed inter-cask transfer operation known as stack-up. The stack-up configuration refers to the condition when the Holtec HI-TRAC (transfer cask), with loaded Multi-Purpose Canister (MPC)
inside, is resting atop the HI-STORM (storage overpack). The breadth of this inspection report is limited and only details the results of the inspection related to the stack-up configuration. The remaining inspection conducted in accordance with IP 60854.1 will be documented in a future inspection report.
The inspectors reviewed licensee design basis documentation associated with a free-standing (no lateral seismic restraint) stack-up configuration. Specifically, the inspectors reviewed the Perry Nuclear Power Plant, 10 CFR 50.59 Evaluation No. 10-03150, Perry Nuclear Power Plant Spent Fuel Dry Storage-Freestanding Cask Configurations, design calculation G58-P-001, Seismic Stability Analysis of HI-TRAC/HI-STORM Stack-up, and design calculation G58-H-HI-2084168, Dynamic Analysis of HI-TRAC/HI-STORM Stack Under Postulated Seismic Events in the Fuel Handling Building @ 620-6 EL.
b.
Observations and Findings
On July 26, 2010, the inspectors received from the Perry Nuclear Power Plant, 10 CFR 50.59 Evaluation No. 10-03150, Perry Nuclear Power Plant Spent Fuel Dry Storage-Freestanding Cask Configurations, and other supporting evaluations used to determine if the freestanding components used in a dry cask storage campaign would require a license amendment request (LAR). Licensee calculation G58-P-001, Seismic Stability Analysis of HI-TRAC/HI-STORM Stack-up, was used to demonstrate dynamic stability of the free-standing stack-up during the vertical transfer operation of the MPC from a HI-TRAC into a HI-STORM while inside the Fuel Handling Building. The calculation used a methodology described in American Society of Civil Engineers (ASCE) Standard 43-05, Seismic Design Criteria for Structures, Systems, and Components in Nuclear Facilities, dated 2005.
The design requirements during MPC transfer operations are specified in the Holtec International HI-STORM 100 Cask System, Revision 7, Final Safety Analysis Report (FSAR) and NUREG-0612, Control of Heavy Loads at Nuclear Power Plants, dated July 1980, provides guidance on defense-in-depth for the control of heavy loads. The inspectors were unable to conclude that the requirements of the Holtec FSAR were met
or that the process conformed to NUREG-0612 guidelines for control of heavy loads.
Specifically Region III inspectors identified a concern with the lack of seismic restraint that would provide lateral stability to the stack-up configuration during transfer of the MPC from the HI-TRAC to the HI-STORM. During this operation, the HI-TRAC is not attached to the single-failure-proof crane. The inspectors noted an increased possibility for the stack-up configuration to tip-over during a seismic event. In addition, the inspectors noted that NUREG/CR-6926, Evaluation of the Seismic Design Criteria in ASCE Standard 43-05 for Application to Nuclear Power Plants, dated March 2007, specified an NRC staff review is required for evaluations utilizing ASCE Standard 43-05 guidance related to dynamic stability of a free-standing rigid body. Since the inspectors could not identify prior NRC staff review of the ASCE Standard 43-05 methodology to evaluate dynamic stability of a rigid body, NRC Region III inspectors concluded that use of this dynamic stability methodology was a departure from a methodology used in the FSAR, and therefore would require an LAR.
Through a Technical Assistance Request (TAR), NRC Region III requested assistance from the Office of Nuclear Material Safety and Safeguards (NMSS) Division of Spent Fuel Storage and Transportation (DSFST) regarding unrestrained vertical transfer operations to: (1) determine whether the licensee was within their licensing basis; (2) perform a technical review and determine acceptability of calculation G58-P-001; (3) provide guidance for inspection of unrestrained vertical transfer operations, if permissible; and (4) evaluate the need for guidance to licensees on acceptable methods of evaluating vertical transfer operations. The TAR was sent to DSFST on October 29, 2010.
DSFST completed its review and provided a response to Region III on February 25, 2011. This response is included as Attachment 2 of this inspection report.
Pertinent excerpts from the TAR response include:
NUREG-0612 provides guidelines for the control of heavy loads at nuclear power plants. The guidelines were developed for all facilities to reduce the potential for the uncontrolled movement of a load or load drop NUREG-0612, p. 1-4. NUREG-0612 further states that the NRC staff has developed an overall philosophy that provides a defense-in-depth approach for controlling the handling of heavy loads. (Emphasis added).
NUREG-0612, p. 5-1. The NUREG provides two paths to achieve defense-in-depth: (1) by providing redundancy (i.e., a single-failure-proof handling system) in the handling of the heavy load; or (2) by providing an analysis of the heavy load drop to show that the evaluation criteria of Section 5.1 of NUREG-0612 are satisfied. If the licensee chooses not to provide redundancy, then even though the licensee may have performed a calculation demonstrating that there is sufficient safety margin such that a load drop is unlikely to occur, the licensee should provide an analysis of the consequences of the heavy load drop to show that the evaluation criteria of Section 5.1 are satisfied.
The stack-up of a HI-TRAC transfer cask on top of a HI-STORM storage cask was an unknown load handling procedure when NUREG-0612 was issued in July 1980. Never-the-less, NUREG-0612 indicates that it reflects
an overall philosophy that provides a defense-in-depth approach for controlling the handling of heavy loads.
The Holtec FSAR recognizes a defense-in-depth approach. Holtec FSAR Section 3.1.2.1.1.1 Tip-Over states the following:
The potential of the HI-STORM 100 Overpack tipping over during the lowering (or raising) of the loaded MPC into (or out of) it with the HI-TRAC cask mounted on it is ruled out because of the safeguards and devices mandated by this FSAR for such operations (Subsection 2.3.3.1 and Technical Specification 4.9). (Emphasis added).
FSAR p. 3.1-9.
Subsection 2.3.3.1 contains a comprehensive set of design criteria for the ancillary equipment and components required for the MPC transfer operations to ensure that the design objective of precluding a kinematic instability event during MPC transfer operations is met.
FSAR p.3.1-9.
Holtec FSAR, Section 2.3.3.1 Equipment states, in part, the following:
Users may effectuate the inter-cask transfer of the MPC between the HI-TRAC transfer cask and either the HI-STORM 100 or the HI-STAR 100 overpack in a location of their choice, depending on site-specific needs and capabilities. For those users choosing to perform the MPC inter-cask transfer using devices not integral to structures governed by the regulations of 10 CFR Part 50 (e.g., fuel handling or reactor building), a Cask Transfer Facility (CTF) is required. FSAR p. 2.3-4.
The detailed design criteria which must be followed for the design and operation of the CTF are set down in Paragraphs A through R FSAR p. 2.3-5.
Holtec FSAR Paragraph A General Specifications subparagraph (iii)
Definitions states that:
the CTF structure is the stationary, anchored portion of the CTF which provides the required structural function to support MPC transfer operations, including lateral stabilization of the HI-TRAC transfer cask and, if required, the overpack, to protect against seismic events.
(Emphasis added). FSAR p. 2.3-7.
Holtec FSAR Paragraph C Heavy Load Handling subparagraph (iii)
Defense-in-Depth states that:
When the HI-TRAC transfer cask is stacked on the overpack, HI-TRAC shall be either held by the lifting device or laterally restrained by the CTF structure. (Emphasis added). FSAR p. 2.3-12.
Holtec FSAR Section 3.1.2.1.1.1 makes it clear that tip-over of the stack-up configuration is ruled out because of the safeguards and devices mandated by the Holtec FSAR in Section 2.3.3.1, which contains design criteria for the devices required to ensure that kinematic instability (tip-over) will not occur.
In structures governed by the regulations of 10 CFR 50, such as the Perry Fuel Handling Building (FHB), where the functional requirements of the CTF can be met by integrally attaching these devices to the building's walls, columns and floor to provide lateral restraint, a separate CTF is not required.
The only facility for which the NRC staff has reviewed and approved a stack-up configuration is the Private Fuel Storage Facility where lateral seismic restraints were provided.
Holtec FSAR Section 2.3.3.1 establishes the design basis for the safety analysis of the stack-up configuration, which is that the HI-TRAC shall be either held by the lifting device or laterally restrained. FSAR p. 2.3-12.
Because of these requirements specified by the FSAR a tip-over of the stacked-up components is ruled out, and therefore an accident analysis for tip-over of the stack-up configuration is not required.
Title 10 CFR 72.212(b)(3) states in part that The general license shall: Review the Safety Analysis Report (SAR) referenced in the Certificate of Compliance, prior to use of the general license, to determine whether or not the reactor site parameters,, are enveloped by the cask design basis considered in these reports.
Title 10 CFR 50.59(c)(2) states in part the following: A licensee shall obtain a license amendment pursuant to §50.90 prior to implementing a proposed change, test, or experiment, if the change, test, or experiment would:...
(v) Create a possibility for an accident of a different type than any previously evaluated in the final safety analysis report;... or (viii) Result in a departure from a method of evaluation described in the FSAR used in establishing the design basis or in the safety analyses.
Title 10 CFR 72.48(c)(2) states in part the following a general licensee shall request that the certificate holder obtain a CoC amendment pursuant to §72.244, prior to implementing a proposed change,... if the change would:
(c)(2)(v) Create a possibility for an accident of a different type than any previously evaluated in the FSAR; or (viii) Result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design basis or in the safety analyses.
The licensees 10 CFR 50.59 evaluation of the stack-up configuration does not address the design basis for the safety analysis of the stack-up configuration found in subsection 2.3.3.1 of the Holtec FSAR, which 10 CFR 72.212 requires the licensee to review. Instead of laterally restraining the HI-TRAC when it is not held by the lifting device, as mandated by the Holtec FSAR, the licensee performed a calculation to demonstrate that the stack-up configuration is dynamically stable. This is a departure from the seismic design basis for the safety analysis of the stack-up configuration, and creates the possibility for an
accident not previously evaluated in Holtec FSAR. The licensee did not perform a 10 CFR 72.48 evaluation.
Because the HI-TRAC is required by the FSAR to be laterally restrained when not held by the lifting device, no accident analysis for the tip-over of the stack-up configuration was performed in the Holtec FSAR. Therefore, not providing lateral restraints is not only a departure from a method of evaluation described in the Holtec FSAR, it also creates a possibility for an accident not previously evaluated in the Holtec FSAR. A 10 CFR 72.48 evaluation, had it been performed, would require the general licensee to request the CoC holder to obtain a CoC amendment pursuant to §72.244 or would require the general licensee to request an exemption.
The Holtec FSAR adheres to the defense-in-depth philosophy of NUREG-0612 for the control and handling of the stack-up configuration. As stated in the Holtec FSAR tipping over during the lowering of the loaded MPC is ruled out because of the safeguards and devices mandated by this FSAR for such operations. The safeguards mandated by the FSAR are that the HI-TRAC shall be either held by the lifting device or laterally restrained Because the tip-over of the laterally supported stack-up configuration is ruled out, no accident analysis for this event is performed in the Holtec FSAR. Furthermore, the bases for the acceptability of the HI-STORM 100 dry cask storage system for such operations are the safeguards and devices mandated within the Holtec FSAR. Rather than providing lateral restraint to the stack-up configuration, the licensee chose to perform a calculation to show that the stack-up is dynamically stable during a seismic event. The NRC staff finds this change to be a substantial departure from the method of evaluation described in the Holtec FSAR that establishes the seismic design basis for the safety analysis of the stack-up configuration. The NRC staff also finds that this change creates the possibility for a tip-over of the stack-up configuration, which is an accident of a different type than previously evaluated in either the Perry FSAR or the Holtec FSAR.
The DSFST staff concluded that Perry should have: (1) provided a lateral restraint system in accordance with the FSAR; (2) requested the certificate holder seek a CoC amendment from the NRC for the HI-STORM 100 Cask System; or (3) requested an exemption from the NRC to allow operations without lateral restraint.
.1 Control of Heavy Loads Design Basis Not Incorporated into Stack-up Configuration during MPC Transfer Operations
A finding of very low safety-significance and associated Non-Cited Violation (NCV) of 10 CFR Part 72.146, Design Control, was identified by the inspectors for the failure of the licensee to incorporate applicable regulatory requirements and the design basis into the seismic evaluation of the stack-up configuration during MPC transfer operations.
Specifically, a dynamic stability determination of the stack-up during a postulated seismic event, in lieu of providing lateral restraints, does not meet design basis requirements as described in the Holtec HI-STORM 100 FSAR.
The inspectors determined that the failure to correctly translate the applicable design basis into specifications, drawings, procedures, and instructions for the control of the
stack-up configuration, was contrary to 10 CFR 72.146, Design Control, and warranted a significance evaluation.
Consistent with the guidance in Section 2.2 of the NRC Enforcement Policy, ISFSIs are not subject to the Significance Determination Process and, thus, traditional enforcement was used for this issue. The inspectors determined that the issue was of more than minor significance using Example 3i of Appendix E, Examples of Minor Issues of Inspection Manual Chapter 0612, Power Reactor Inspection Reports. Specifically, the licensees determination to not install lateral seismic restraint to the stack-up configuration created the possibility for an accident of a different type than any previously evaluated in the FSAR and that this configuration required additional accident analyses to be performed. The inspectors determined that the issue could be evaluated using example 6.1.d.2 of the NRC Enforcement Policy as a Severity Level IV violation because the licensee had not performed an MPC transfer operation and NRC intervention resulted in the licensee postponing their ISFSI campaign.
Title 10 CFR 72.146, Design Control, requires, in part, that the licensee, applicant for a license, certificate holder, and applicant for a CoC shall establish measures to ensure that applicable regulatory requirements and the design basis, as specified in the license or CoC application for those structures, systems, and components to which this section applies, are correctly translated into specifications, drawings, procedures and instructions. Further, it requires that the design control measures must provide for verifying or checking the adequacy of design methods such as design reviews, alternate or simplified calculation methods, or by a suitable testing program.
Contrary to the above, as of July 26, 2010, the licensee failed to establish measures to ensure that applicable regulatory requirements and the design basis, as specified in the license or CoC application for those structures, systems, and components to which this section applies, were correctly translated into specifications, drawings, procedures, and instructions. Specifically, calculation number G-58-P-001 failed to incorporate seismic restraint of the stack-up configuration during MPC transfer operations. A tip-over of the restrained configuration during a postulated seismic event is ruled out in the Holtec HI-STORM FSAR because of these mandated safeguards and devices. Because this issue is of very low safety-significance (Severity Level IV), and has been entered into the licensees corrective action program in condition report (CR) 10-84670, this violation is being treated as an NCV consistent with Section 2.3.2 of the NRC Enforcement Policy.
(NCV 072-00069/11-002-01)
.2 Dynamic Stability Analysis Observations
As part of the Region III TAR, a sample of licensee dynamic stability calculations was submitted for staff technical review and staff guidance related to inspection of unrestrained vertical transfer operations. These comments are included in Attachment 2.
Although NRC staff identified potential technical issues during the review of calculations G58-P-001 and G58-H-HI-2084168, the issue of the licensees failure to provide lateral restraint to the stack-up configuration was evaluated above in Section 1.b.1. The licensee has entered the concern into their corrective action program as CR10-84670.
Final licensee corrective actions related to the stack-up will be subject to future NRC inspection.
.3 50.59/72.48 Safety Evaluation Observations
In NRC Regulatory Guide 1.187, Guidance for Implementation of 10CFR 50.59 Changes, Tests and Experiments, dated November 2000, NRC staff endorsed Revision 1 of Nuclear Energy Institute (NEI) 96-07, Guidelines for 10 CFR 50.59 Evaluations, for complying with the provisions of 10 CFR 50.59. Regulatory Guide 1.187 also states, in-part, that NEI 96-07 is also generally applicable to evaluations performed by licensees of ISFSIs or spent fuel storage cask design certificate holders for implementation of the revised 10 CFR 72.48.
Section 4.3.8 of NEI 96-07, Does the Activity Result in a Departure from a Method of Evaluation Described in the USFAR Used in Establishing the Design Bases or in the Safety Analyses? guidance indicates, in-part, that another methodology previously accepted by the NRC through issuance of a safety evaluation report (SER) is not considered a departure from an evaluation described in the UFSAR. As noted in Section 1.b above, the only facility for which the NRC staff has reviewed and approved a stack-up configuration is the Private Fuel Storage Facility where lateral seismic restraints were provided.
NRC staff guidance to inspectors related to the unrestrained stack-up configuration, provided in Attachment 2, included in-part:
For the inspection of a freestanding (unrestrained) stack-up configuration, the inspectors shall request the general licensee to provide the documentation approving the unrestrained stack-up configuration used to perform vertical transfer operations and the associated NRC staff SER. In the absence of such documentation vertical transfer operations shall be postponed until either documentation approving such operations can be provided or a system of lateral restraints has been installed.
Although NRC staff identified potential issues during the review of the licensees 10 CFR 50.59 evaluation including the lack of a 10 CFR 72.48 evaluation, the issue of the licensees failure to provide lateral restraint to the stack-up configuration was evaluated above in Section 1.b.1. The licensee has entered the concern into their corrective action program as CR10-84670. Final licensee corrective actions related to the stack-up will be subject to future NRC inspection.
c.
Conclusion
The inspectors determined that the failure to correctly translate the applicable design basis into specifications, drawings, procedures, and instructions for the control of stack-up configuration, was contrary to 10 CFR 72.146, Design Control. The NRC staff finds that not restraining the stack-up evolution is a substantial departure from the method of evaluation described in the Holtec FSAR that establishes the seismic design basis for the safety analysis of the stack-up configuration. NRC staff also finds that this change creates the possibility for a tip-over of the stack-up configuration, which is an accident of a different type than previously evaluated in either the Perry FSAR or the Holtec FSAR.
Based on these findings the licensee should have laterally restrained the stack-up, requested an exemption, or requested the certificate holder to seek an amendment.
Because this matter was of very low safety-significance (Severity Level IV), and has been entered into the licensees corrective action program CR10-84670, this violation is being treated as an NCV consistent with the NRC Enforcement Policy.
2.0 Exit Meeting Summary
On March 4, 2011, the inspectors presented the inspection results to Mr. V. Veglia and other members of the licensee staff via teleconference. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.
ATTACHMENTS:
1. Supplemental Information 2. Response to Region III Technical Assistance Request, Evaluation of Freestanding Stack-up Configuration
Attachment 1 SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
Licensee
V. Veglia - Director, Fleet Project Management R. Coad - Manager, Perry Regulatory Compliance J. Fox - Manager, Fleet Project Management (Acting Dry Cask Storage Project Manager)
T. Hilston - Manager, Perry Design Engineering T. Lentz - Manager, Fleet Licensing N. Bonner - Dry Cask Storage Project B. Spiesman - Fleet Licensing S. Thomas - Perry Site Projects L. Zerr - Perry Regulatory Compliance
INSPECTION PROCEDURES USED
IP 60854.1 Preoperational Testing of an Independent Spent Fuel Storage Facility (ISFSI) at Operating Plants
ITEMS OPENED, CLOSED, AND DISCUSSED Opened 072-00069/11-002-01 NCV Control of Heavy Loads Design Basis Not Incorporated into Stack-up Configuration during MPC Transfer Operations (Section 1.b.1)
Closed 072-00069/11-002-01 NCV Control of Heavy Loads Design Basis Not Incorporated into Stack-up Configuration during MPC Transfer Operations (Section 1.b.1)
Discussed None.
LIST OF DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection. Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort. Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.
10 CFR 50.59 Screen No. 10-3150; Perry Nuclear Power Plant Spent Fuel Dry Storage - Free Standing Stack Configurations; Revision 0 dated July 21, 2010
10 CFR 50.59 Evaluation No. 10-3150; Perry Nuclear Power Plant Spent Fuel Dry Storage -
Free Standing Stack Configurations; Revision 0 dated July 23, 2010
Attachment 1 Calculation G58-P-001; Seismic Stability Analysis of HI-TRAC/HI-STORM Stack-up; Revision 0 dated July 26, 2010
Calculation G58-H-HI-2084168; Dynamic Analysis of HI-TRAC/HI-STORM Stack Under Postulated Seismic Events in the Fuel Handling Building @ 620-6 El.; Revision 0 dated July 22, 2010
Condition Report CR10-84670; NRC Issues Identified with 50.59 Evaluation of Dry Fuel Component Stackup in FHB; dated October 22, 2010
LIST OF ACRONYMS USED
ADAMS Agencywide Document Access Management System ASCE American Society of Civil Engineers CoC
Certificate of Compliance CR
Condition Report CFR
Code of Federal Regulations CTF
Cask Transfer Facility DNMS Division of Nuclear Material Safety DSFST Division of Spent Fuel Storage and Transportation FHB
Fuel handling Building FSAR Final Safety Analysis Report IP
Inspection Procedure ISFSI Independent Spent Fuel Storage Installation LAR
License Amendment Request PARS Publicly Available Records System MPC Multi-Purpose Canister NCV
Non-Cited Violation NMSS NRC Office of Nuclear Material Safety and Safeguards NRC
U.S. Nuclear Regulatory Commission SAR
Safety Analysis Report SER
Safety Evaluation Report TAR
Technical Assistance Request