IR 07200008/2021001
| ML22013A002 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs, 07200078  |
| Issue date: | 01/13/2022 |
| From: | Anthony Dimitriadis Division of Nuclear Materials Safety I |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2021001 | |
| Download: ML22013A002 (13) | |
Text
January 13, 2022
SUBJECT:
CALVERT CLIFFS NUCLEAR POWER PLANT - INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) NRC INSPECTION REPORT NO.
07200008/2021001
Dear Mr. Hanson:
On December 9, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of the Calvert Cliffs Nuclear Power Plant (Calvert Cliffs) Independent Spent Fuel Storage Installation (ISFSI) activities. Onsite inspections were performed on September 27 -
29, 2021, October 26 - 28, 2021, and November 1 - 10, 2021. Additional inspection activities (in office reviews via remote means) were conducted throughout the period as a consequence of the COVID-19 public health emergency (PHE). The inspectors examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations, and the conditions of your license and the Certificate of Compliance (CoC). The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records, and plant walkdowns. The results of this inspection were discussed with Mr. Thomas Haaf, Site Vice President, and other members of your staff on December 15, 2021, and are documented in the enclosed report.
The report documents one licensee-identified violation of NRC requirements of very low safety significance (Severity Level IV). Because of the very low safety significance and because it was entered into your corrective action program, the NRC is treating the violation as a Non-Cited Violation (NCV) consistent with Section 2.3.2.a of the NRC Enforcement Policy.
If you contest the violation or the significance of the 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 copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector Office at the Calvert Cliffs Nuclear Power Plant.
In accordance with Title 10 Code of Federal Regulations (CFR) 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the NRC document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.
Current NRC regulations and guidance are included on the NRC's Web site at www.nrc.gov; select Radioactive Waste; Decommissioning of Nuclear Facilities; then Regulations, Guidance and Communications. The current Enforcement Policy is included on the NRC's website at www.nrc.gov; select About NRC, Organizations & Functions; Office of Enforcement; Enforcement documents; then Enforcement Policy (Under 'Related Information'). You may also obtain these documents by contacting the Government Printing Office (GPO) toll-free at 1-866-512-1800. The GPO is open from 8:00 a.m. to 5:30 p.m. EST, Monday through Friday (except Federal holidays).
No reply to this letter is required. Please contact Briana DeBoer at 610-337-5370 if you have any questions regarding this matter.
Sincerely, Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Radiological Safety and Security Docket Nos: 07200008 and 07200078 License Nos: DPR-53 and DPR-69 Enclosure:
Inspection Report 07200008/2021001 w/Attachment: Supplemental Information cc w/encl:
Distribution via ListServ Anthony M.
Dimitriadis Digitally signed by Anthony M. Dimitriadis Date: 2022.01.13 10:43:12 -05'00'
EXECUTIVE SUMMARY
Exelon Generation Company, LLC
Calvert Cliffs Nuclear Power Plant NRC Inspection Report No. 07200008/2021001
On December 9, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of the Independent Spent Fuel Storage Installation (ISFSI) activities at Calvert Cliffs Nuclear Power Plant. Onsite inspections were performed for dry run operations for spent fuel pool operations on September 27 - 29, 2021 and for transportation on October 26 - 28, 2021.
An onsite inspection of the initial Holtec dry cask loading at Calvert Cliffs was performed on November 1 - 10, 2021. Additional inspection activities (in office reviews via remote means)were performed throughout this period as a consequence of the COVID-19 public health emergency (PHE). The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records, and plant walkdowns. The NRCs program for overseeing the safe operation of dry storage of spent fuel at an ISFSI is described in Inspection Manual Chapter 2690, Inspection Program for Dry Storage of Spent Reactor Fuel at Independent Spent Fuel Storage Installations and for 10 Code of Federal Regulations (CFR)
Part 71 Transportation Packagings.
List of Violations
A Severity Level IV Non-Cited Violation (NCV), of 10 CFR 72.212 (b)(1) was identified by the licensee because Exelon Generation, LLC (Exelon), did not notify the NRC using instructions in 10 CFR 72.4 at least 90 days before first storage of spent fuel under their general license. Specifically, Calvert Cliffs first storage of spent fuel using Certificate of Compliance (CoC) 1032, Amendment 1, Revision 1, occurred on November 9, 2021 and the letter notifying the NRC was sent on October 22, 2021.
REPORT DETAILS
1.0 Independent Spent Fuel Storage Installation
1.1 Background
Owner/Operator Exelon - Calvert Cliffs Nuclear Power Plant (Calvert Cliffs), selected Holtec HI-STORM FW Cask System technology to allow spent nuclear fuel assemblies currently stored at Calvert Cliffs spent fuel pool (SFP) to be relocated and stored using an ISFSI. The Holtec system is listed in 10 CFR 72.214, List of Approved Spent Fuel Storage Casks, under Certificate of Compliance (CoC) No. 1032. Holtec Final Safety Analysis Report (FSAR), Revision 4, applies to the Holtec ISFSI system that was placed in service under CoC number 1032.
1.2 Onsite Fabrication of Components and Construction of an ISFSI (IP 60853)
a. Inspection Scope
The ISFSI pads located at Calvert Cliffs were designed and constructed to store dry shielded canisters (DSCs) in TN NUHOMS Horizontal Storage Modules (HSMs) on nine separate pad foundations. At the time of this inspection, 94 DSCs had been stored in NUHOMS HSMs located on the Calvert Cliffs ISFSI pads. Exelon plans to load up to 35 HI-STORM FW units on two of the existing storage pads. The inspectors reviewed the evaluations to ensure a demonstration of reasonable assurance that the ISFSI pad at Calvert Cliffs complies with the requirements of 10 CFR 72.212(b)(5)(ii). The inspectors performed a review of the structural assessment of the ISFSI pad design for static and dynamic loads associated with the new casks, as required by 10 CFR 72.212. In addition, the inspectors reviewed the tip over analysis of the HI-STORM FW storage cask and the soil structure interaction analysis performed for Calvert Cliffs. The inspectors focused their review on completeness and accuracy of the information provided by Exelon and verified that the analysis and design methodology used for the additional HI-STORM casks on the Calvert Cliffs ISFSI pad was consistent with the HI-STORM FW FSAR as well as applicable guidance in American Concrete Institute (ACI)318, ACI 349, NUREG-1536, NUREG-2215 and NUREG-0800. The staff concluded that Exelons overall approach was reasonable, satisfied the requirements of 10 CFR 72.212(b)(5)(ii), and therefore provides a reasonable assurance of safety.
b. Findings
No violations of more than minor significance were identified.
1.3 Pre-operational Testing of an ISFSI (IP 60854)
a. Inspection Scope
The inspectors evaluated Exelons performance during NRC observed pre-operational dry run activities that were performed in order to fulfill requirements in the NRC-issued CoC No. 1032, Amendment 1, Revision 1 (CoC 1032-1R1). The inspectors observed Exelons dry run activities related to SFP operations at Calvert Cliffs on September 27 - 29, 2021 and transportation operations on October 26 - 28, 2021.
During the dry run activities, the inspectors observed cask loading and cask movement activities to determine whether Exelon had developed the capability to properly load and move the multipurpose canister (MPC) to be used in storage of spent fuel at Calvert Cliffs. The inspectors observed:
- (a) movement of a dummy fuel assembly into the MPC,
- (b) movement of the MPC/HI-TRAC from the fuel pool to the Cask Processing Area (c)stack-up and transfer of the MPC from the HI-TRAC to the HI-STORM
- (d) retrieval of the MPC from the HI-STORM and movement back into the HI-TRAC,
- (e) installation of the HI-STORM lid,
- (f) transport of the HI-STORM on the HI-PORT from the auxiliary building truck bay to the ISFSI pad area.
The inspectors attended select Exelon pre-job briefings to assess Exelons ability to identify critical steps of the evolution, potential failure scenarios, and human performance tools to prevent errors. The inspectors reviewed the training program and training records of personnel assigned to ISFSI activities. The inspectors reviewed MPC loading, unloading, and processing procedures to determine if they contained commitments and requirements specified in the CoC, technical specifications (TSs),
UFSAR, and Title 10 of the CFR Part 72. The inspectors also reviewed Exelons fuel selection procedures to ensure they appropriately incorporated the requirements in the TSs.
The inspectors reviewed radiation protection procedures and radiation work permits associated with the proposed ISFSI loading campaign. The inspectors also reviewed the radiological controls which would be established during an MPC loading campaign and also reviewed corrective action reports associated with preparations for the ISFSI loading campaign to ensure that issues were being properly identified, prioritized, and evaluated commensurate with their safety significance.
b. Findings
No violations of more than minor significance were identified.
1.4 Operation of an ISFSI at Operating Plants (IP 60855)
a. Inspection Scope
From November 1 - 10, 2021, the inspectors observed and evaluated Exelons loading of the first MPC associated with its initial Holtec HI-STORM FW Cask System dry cask campaign onsite at Calvert Cliffs. The inspectors also reviewed the licensees planned activities associated with long-term operation and monitoring of the ISFSI. The inspectors evaluated compliance with the CoC, TSs, and station procedures.
The inspectors observed fuel assemblies being loaded into the MPC. The inspectors also observed MPC processing operations including welding, non-destructive weld examinations, hydrostatic testing, vacuum drying, helium backfill, and survey activities.
The inspectors also observed movement activities including stack-up, vertical cask transporter (VCT) operation, and placement of the HI-STORM at its final location on the pad. During performance of these activities, the inspectors verified that procedure use, communication, and coordination of ISFSI activities met established Exelon standards and requirements.
The inspectors reviewed Calvert Cliffs program associated with fuel characterization and selection for storage and reviewed the first cask fuel selection package to determine if the licensee was loading fuel in accordance with the CoC, TSs, and procedures. Inspectors reviewed a recording made of the fuel assemblies loaded into the first MPC to ensure the loading was in accordance with Calvert Cliffs loading plan.
The inspectors observed radiation protection surveys and job coverage for the cask loading workers, and reviewed survey data maps and radiological records from the first MPC loading to determine if radiation survey levels measured were within limits specified by the TSs and consistent with values specified in the FSAR.
The inspectors reviewed corrective action reports and the associated follow-up actions that were generated since Calvert Cliffs dry run demonstrations, to ensure that issues were entered into the corrective action program (CAP), prioritized, and evaluated commensurate with their safety significance.
b. Findings
72.212 (b)(1) states, in part, the general licensee must: Notify the Nuclear Regulatory Commission using instructions in 10 CFR 72.4 at least 90 days before first storage of spent fuel under this general license. The notice may be in the form of a letter, but must contain the licensees name, address, reactor license and docket numbers, and the name and means of contacting a person responsible for providing additional information concerning spent fuel under this general license. A copy of the submittal must be sent to the administrator of the appropriate Nuclear Regulatory Commission regional office listed in Appendix D to Part 20 of this chapter.
Contrary to the above, Exelon did not notify the NRC using instructions listed in 10 CFR 72.4 at least 90 days before first storage of spent fuel under their general license.
Specifically, Calvert Cliffs first storage of spent fuel using Certificate of Compliance (CoC)1032, Amendment 1, Revision 1, occurred on November 9, 2021 and the letter notifying the NRC was sent on October 22, 2021. Because this violation was of low safety significant and entered into Calvert Cliffs CAP as IR 04454819, the issue was non-repetitive or willful, and this issue was identified by the licensee, this is being treated as a Severity Level IV, Non-Cited Violation (NCV), consistent with Section 2.3.2.a of the Enforcement Policy.
1.5 Review of 10 CFR 72.212
- (b) Evaluations (IP 60856)
a. Inspection Scope
Calvert Cliffs is utilizing the Holtec International HI-STORM FW Cask System for the storage of spent fuel at the onsite ISFSI. The HI-STORM FW casks augment the Standardized NUHOMS HSMs already in service at the current ISFSI, which began operation in 1992.
The review of the HI-STORM FW Cask System was based on NRC-issued CoC 1032-1R1 and its associated Safety Evaluation Report (SER), and HI-STORM FW FSAR Revision 4. The review of the Part 50 facility site-specific parameters utilized the Calvert Cliffs UFSAR, and other applicable plant-specific design and licensing basis information.
The inspectors evaluated the licensees compliance with the requirements of 10 CFR 72.212. The inspectors examined Exelons written evaluations to determine if they were in accordance with 10 CFR 72.212(b)(5) and evaluated the conditions set forth in the CoC to determine if conditions had been met prior to use and if the radiological requirements of 72.104 were met. The inspectors examined applicable reactor site parameters, such as hypothetical fire and explosions, tornadoes, wind-generated missile impacts, seismic qualifications, lightning, flooding and temperature, to determine if they had been evaluated for acceptability with bounding values specified in the FSAR and the NRC SER. The inspectors also examined 50.59 evaluations associated with the construction and operation of the ISFSI and plant interfaces to determine if they were performed and to determine if changes to certain facility design bases and UFSAR commitments required NRC approval. The reactor emergency plan, quality assurance program, training program, and radiation protection program were reviewed to determine if there was a decrease in effectiveness and if changes made required prior NRC approval.
b. Findings
No violations of more than minor significance were identified.
2.0 Exit Meeting
On December 15, 2021, the inspectors presented the inspection results to Mr. Thomas Haaf, Site Vice President, and other members of the Exelon staff who acknowledged the inspection results. No proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
Licensee
- T. Haaf, Site Vice President
- A. Abady, Senior Engineer
- L. Daniels, Dry Cask Storage Project Manager
- J. Governale, Holtec Dry Cask Storage Project Manager
- M. Governale, Cask Loading Supervisor (Holtec)
- K. Greene, Regulatory Assurance
- P. Gregory, Dry Cask Storage Senior Program Manager
- T. Monk, Cask Loading Supervisor (Holtec)
- A. Simpson, Regulatory Assurance
ITEMS OPENED, CLOSED, AND DISCUSSED
None
LIST OF DOCUMENTS REVIEWED
Section 1.2 Onsite Fabrication of Components and Construction of an ISFSI (IP 60853)
Calculations
Calc No. 11562-012-ST-2, Seismic Soil-Structure Interaction Analysis of ISFSI Pad, Revision 0,
dated August 22, 2009
HI-2188443, Soil Structure Interaction (SSI) Analysis of ISFSI Pad at Calvert Cliffs, Revision 0
HI-2200883, Structural Analysis of ISFSI Pad at Calvert Cliffs, Revision 0
Miscellaneous
ASCE 4-98, Seismic Analysis of Safety-related Nuclear Structures
RRTI-2845-001, Revision 0, dated August 15, 2018
CFR 72.212 Evaluation Report for the HI-STORM FW MPC Storage System, Revision 0
Section 1.3 Preoperational Testing of an ISFSI (IP 60854)
Calculations
HI-2188258, VCT Seismic Stability Analysis for Calvert Cliffs (CCNPP), Revision 7
HI-2200226, Seismic Stability Analysis of Hi-Storm on Hi-Port at Calvert, Revision 6
Corrective Action Issue Reports (IRs)
04454598
04454856
04455922
04456137
04456234
04456468
04458047
Miscellaneous
Work Order C93787943, ISFSI: NRC Dry Run Phase 4
Procedures
HPP-2848-100, MPC Pre-Operation Inspection at Calvert, Draft D, Revision 0
HPP-2848-200, MPC Loading at Calvert, Draft C, Revision 0
HPP-2848-300, MPC Processing at Calvert, Draft B, Revision 0
Procedures (Contd)
HPP-2848-400, MPC Transfer at Calvert, Draft B, Revision 0
HPP-2848-500, HI-STORM Operations and Transport at Calvert Cliffs, Draft B, Revision 0
HPP-2848-600, MPC Unloading at Calvert, Draft B, Revision 0
HPP-2848-700, Response to Abnormal Conditions at Calvert, Draft A, Revision 0
HPP-2848-800, Ambient Temperature Monitoring at Calvert, Draft A, Revision 0
MA-AA-716-008-1008, Refuel Floor FME Plan, Revision 18
OI-25A, Spent Fuel Handling Machine, Revision 05800
RP-AA-300-1005, Removing Items from the Spent Fuel Pool, Reactor Cavity, and Equipment Pit,
Revision 4
RP-AA-305, Holtec HI-TRAC Radiation Survey, Revision 8
RP-AA-306, Holtec HI-STORM Radiation Survey, Revision 6
RP-AA-401-1006, Controls for ISFSI Associated Activities, Revision 2
Section 1.4 Operation of an ISFSI at Operating Plants (IP 60855)
Corrective Action Issue Reports (IRs)
04457915
Miscellaneous
ALARA Plan Number 21Q-0011, 2021 ISFSI Campaign (Dry Fuel Storage using Hol-Tech System),
dated August 20, 2021
CA10501, Fuel Selection Packages CAL-0095 to CAL-0097 for MPCs 168 to 170 - ISFSI, Revision 0
Calvert Cliffs AMBD-ISFSI, Aging Management Program (AMP) Effectiveness Review, dated
December 18, 2020
Letter to NRC dated October 22, 2021, Initial Spent Fuel Loading Campaign
NOSA-CAL-20-10, Independent Spent Fuel Storage Installation Audit Report, dated October 7, 2020
RWP CC-0-21-00204, Dry Cask Activities, Revision 00
RWP CC-0-21-00205, Dry Cask Activities with Added Controls On-line, Revision 00
Procedures
OU-CA-630-100, MPC Pre-Operation Inspection at Calvert, Revision 1
OU-CA-630-200, MPC Loading at Calvert (HPP-2845-200), Revision 1
OU-CA-630-300, MPC Processing at Calvert, Revision 1
OU-CA-630-400, MPC Transfer at Calvert, Revision1
OU-CA-630-500, HI-STORM Movements at Calvert (HPP-2845-500), Revision 1
OU-CA-630-600, MPC Unloading at Calvert, Revision 1
OU-CA-630-700, Response to Abnormal Conditions at Calvert, Revision 1
OU-CA-630-800, Ambient Temperature Monitoring at Calvert, Revision 1
Section 1.5 Review of 10 CFR 72.212 (b) Evaluations (IP 60856)
CFR 50.59 and 10 CFR 72.48 Screenings/Evaluations
ECP-18-000512-72.48-Coversheet, Holtec HI-STORM FW Dry Cask Systems - Licensing &
Operations, Revision 3
ECP-18-000512-72.48-Screening-01, Revision 1
Holtec 72.48 #1124, dated April 9, 2015
Calculations
HI-2135869, Site-Specific Tornado Missile Analysis for HI-STORM FW System
HI-2188258, VCT Seismic Stability Analysis for Calvert Cliffs (CCNPP), Revision 7
HI-2188355, Seismic Analysis of HI-TRAC VW on Cask Pedestal in the Cask Pit Loading Area
Calculations (Contd)
HI-2188445, HI-TRAC/HI-STORM/HI-PORT Stack up Analysis for Calvert, Revision 8
HI-2188602, Evaluation of VCT/HI-PORT Fire Event on HI-STORM FW for Calvert Cliffs
HI-2200226, Seismic Stability Analysis of HI-STORM on HI-PORT at Calvert, Revision 6
Corrective Action Issue Reports (IRs)
04456237
Miscellaneous
CFR 72.212 Evaluation Report for the HI-STORM FW MPC Storage System, Calvert Cliffs Nuclear
Power Plant, Revision 0
CFR 72.212 Evaluation Report for the HI-STORM FW MPC Storage System, Calvert Cliffs Nuclear
Power Plant, Draft 10/8/2021
CY-AA-170-1000, Radiological Environmental Monitoring Program and Meteorological Program
Implementation, Revision 12
CY-AA-170-2000, Annual Radioactive Effluent Release Report, Revision 10
ECO #45, Revision 0, dated March 16, 2015
ECP-18-000512, Holtec HI-STORM FW Dry Cask Systems, Licensing & Operations, Revision 4
HSP-345, Important to Safety Classification Procedure, Revision 5
MA-AA-716-022, Control of Heavy Loads Program, Revision 15
NO-AA-10, Exelon Nuclear Quality Assurance Topic Report (QATR), Revision 97
Purchase Specification for the Vertical Cask Transporter, Designation No. PS-1120, Revision 9
RRTI-2845-001, Revision 0, dated August 15, 2018
RRTI-2845-003, Responses to NRC Comments for VCT, Revision 0
Procedures
EP-AA-1011 Addendum 3, Calvert Cliffs Nuclear Power Plant Emergency Action Levels, Revision 7
HPP-2848-100, MPC Pre-Operation Inspection at Calvert, Draft D, Revision 0
HPP-2848-200, MPC Loading at Calvert, Draft C, Revision 0
HPP-2848-300, MPC Processing at Calvert, Draft B, Revision 0
HPP-2848-400, MPC Transfer at Calvert, Draft B, Revision 0
HPP-2848-500, HI-STORM Operations and Transport at Calvert Cliffs, Draft B, Revision 0
HPP-2848-600, MPC Unloading at Calvert, Draft B, Revision 0
HPP-2848-700, Response to Abnormal Conditions at Calvert, Draft A, Revision 0
HPP-2848-800, Ambient Temperature Monitoring at Calvert, Draft A, Revision 0
LS-AA-114, Exelon 72.48 Review Process, Revision 4
MA-AA-716-021, Rigging and Lifting Program, Revision 32
OU-AA-630-101, Dry Cask Storage/ISFSI Inspection Surveillance Program, Revision 3
PI-AA-115, Operating Experience Program, Revision 5
PI-AA-125, Corrective Action Program (CAP) Procedure, Revision 7
LIST OF ACRONYMS USED
American Concrete Institute
Calvert Cliffs
Calvert Cliffs Nuclear Power Plant
Corrective Action Program
Certificate of Compliance
CoC 1032 - 1R1
Certificate of Compliance 1032, Amendment 1, Revision 1
CFR
Code of Federal Regulations
Dry Shielded Canister
Exelon
Exelon Generation, LLC
Final Safety Analysis Report
HSM
Horizontal Storage Module
Independent Spent Fuel Storage Installation
Multipurpose Canister
Non-Cited Violation
NRC
U.S. Nuclear Regulatory Commission
Public Health Emergency
Safety Evaluation Report
Spent Fuel Pool
TS
Technical Specifications
Updated Final Safety Analysis Report
Vertical Cask Transporter