IR 07200067/2020002
| ML21021A284 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 01/21/2021 |
| From: | Anthony Dimitriadis Decommissioning Branch I |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2020002 | |
| Download: ML21021A284 (12) | |
Text
January 21, 2021
SUBJECT:
R.E. GINNA NUCLEAR POWER PLANT - INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) NRC INSPECTION REPORT NO.
07200067/2020002
Dear Mr. Hanson:
On November 16, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of the R.E. Ginna Nuclear Power Plant (Ginna) Independent Spent Fuel Storage Installation (ISFSI) activities. On-site inspections of the canister processing dry run were performed on August 3-5, 2020, at the Holtec training facility in Camden, New Jersey.
Additional on-site dry run inspections were conducted at Ginna on August 26-28, 2020 and September 14-17, 2020. On-site inspections of the initial Holtec dry cask loading were performed on October 26-30, 2020. 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, and a review of procedures and records. The results of this inspection were discussed with Mr. Paul Swift, Site Vice-President, and other members of your staff on December 11, 2020, and are documented in the enclosed report.
No findings or violations were identified during this inspection.
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, if any 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 John Nicholson at 610-337-5236 if you have any questions regarding this matter.
Sincerely,
/RA/
Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Nuclear Materials Safety Docket No: 07200067 License No: DPR-18
Enclosure:
Inspection Report 07200067/2020002 w/Attachment: Supplemental Information
REGION I==
Inspection Report
Docket No:
072-00067
License No:
Report No:
07200067/2020002
Licensee:
Exelon Generation Company, LLC
Facility:
R.E. Ginna Nuclear Power Plant
Location:
Ontario, New York
Dates:
August 3 - November 16, 2020
Inspectors:
J. Nicholson, Senior Health Physicist
P. Patel, Structural Engineer
A. Rigato, Structural Engineer
R. Rodriguez, Structural Engineer
J. Schoppy, Senior Reactor Inspector
J. Tapp, Transportation and Storage Safety Inspector
K. Warner, Senior Health Physicist
Approved by:
Anthony Dimitriadis, Chief
Decommissioning, ISFSI, and Reactor HP Branch
Division of Nuclear Materials Safety, Region I
ii
Enclosure
EXECUTIVE SUMMARY
Exelon Generation Company, LLC
R.E. Ginna Nuclear Power Plant NRC Inspection Report No. 07200067/2020002
On November 16, 2020, the U.S. Nuclear Regulatory Commission (NRC) competed a period of on-site and remote inspections of Ginnas Independent Spent Fuel Storage Installation (ISFSI)activities. On-site inspections were performed for dry run operations for canister processing on August 3-5, 2020 at Holtecs training facility in Camden, New Jersey and at Ginna on August 26-28 for transportation, and September 14-17, 2020, for spent fuel pool operations. An on-site inspection of the initial Holtec dry cask loading at Ginna was performed on October 26-30, 2020. 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), ending with the completion of the initial Holtec four cask loading campaign on November 16, 2020. The inspections consisted of observations by the inspectors, interviews with site personnel, and a review of procedures and records. 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.
No findings or violations were identified during this inspection.
REPORT DETAILS
1.0 Independent Spent Fuel Storage Installation
1.1 Background
Owner/Operator Exelon - R.E. Ginna Nuclear Power Plant (Ginna), selected Holtec HI-STORM 100 Cask System technology to allow spent nuclear fuel assemblies currently stored at Ginnas 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. 1014. Holtec updated Final Safety Analysis Report (UFSAR), Revision 18 applies to the Holtec ISFSI system that was placed in service at Ginna under CoC number 1014.
1.2 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 Certificate of Compliance (CoC) No. 1014, Amendment 13. The inspectors observed Exelons dry run activities related to canister processing on August 3-5, 2020, at Holtecs facility in Camden, New Jersey. Additional dry run activity inspections were performed at Ginna on August 26-28 for transportation operations, and September 14-17, 2020 for spent fuel pool operations.
Observations and Findings - Dry Run Activities
During the inspection period, the inspectors observed cask processing activities to determine whether Exelon had developed, implemented, and evaluated preoperational testing activities to safely process the multi-purpose canister (MPC) to be used in storage of spent fuel at Ginna. The inspectors observed MPC activities including blowdown, vacuum drying, helium backfilling, and hydrogen monitoring. The inspectors verified that the vacuum drying system was leak tight and the helium flow path was operable. The inspectors examined the MPC processing equipment and reviewed worker qualification records. The inspectors also observed cask loading and cask movement activities to determine whether Exelon had developed the capability to properly load and move the MPC to be used in storage of spent fuel at Ginna. The inspectors observed:
- (a) movement of a dummy fuel assembly into the MPC,
- (b) down-ending the HI-TRAC transfer cask/MPC onto the self-propelled motorized transporter (SPMT),
- (c) transportation of the HI-TRAC/MPC to the ISFSI pad,
- (d) upending the HI-TRAC/MPC, stack-up and transfer of the MPC from the HI-TRAC to the HI-STORM at the cask transfer pit (CTP),
- (e) retrieval of the MPC from the HI-STORM back into the HI-TRAC,
- (f) installation of the HI-STORM lid,
- (g) lifting of the HI-STORM out of the CTP, and
- (h) placement of the HI-STORM on the ISFSI pad.
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),
Final Safety Analysis Report (FSAR), 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.
No findings of significance were identified.
1.3 Operation of an ISFSI at Operating Plants (IP 60855)
a. Inspection Scope
From October 26-30, 2020, the inspectors observed and evaluated Exelons loading of the first MPC associated with its initial Holtec HI-STORM 100 Cask System dry cask campaign on-site at Ginna. The inspectors also evaluated Exelons loading of the subsequent Holtec HI-STORM 100 casks for the initial loading campaign via remote means (in-office reviews) through November 16, 2020. 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.
Observations and Findings - Loading Operations
The inspectors observed fuel assemblies being loaded into the MPC and processing operations including installation of the automated welding system, welding, non-destructive weld examinations, blowdowns, vacuum drying, helium backfill, and survey activities. 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 Ginnas 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 Ginnas 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. Due to higher than expected doses with the first cask and weld repair of the HI-TRAC transfer cask, the inspectors followed up on the remainder of the four cask loading campaign via remote means (in-office reviews) through November 16, 2020, to further evaluate performance.
During transport of the first loaded MPC to the pad, Exelon discovered a small water leak near the bottom trunnion of the HI-TRAC transfer cask. The work was paused as the site personnel conducted a review and discovered that the water emanated from the water jacket associated with the HI-TRAC. It was determined that the cause of the leak was from a weld defect due to a manufacturing/weld design flaw found on one side of the cask by the trunnion. The other trunnion did not exhibit the same defect. Exelon and the dry cask vendor drafted a repair plan that was reviewed by an independent consultant. A weld repair of the HI-TRAC was performed. The inspectors reviewed the repair plan, documentation, and testing of the completed repair and found it to be acceptable.
The inspectors reviewed corrective action reports and the associated follow-up actions that were generated since Ginnas dry run demonstrations to ensure that issues were entered into the corrective action program, prioritized, and evaluated commensurate with their safety significance.
No findings of significance were identified.
1.4 Review of 10 CFR 72.212
- (b) Evaluations (IP 60856)
a. Inspection Scope
The licensee is utilizing the Holtec International HI-STORM 100 Cask System for the storage of spent fuel at the onsite ISFSI. The HI-STORM 100 casks augment the Standardized NUHOMS casks already in service at the current ISFSI, which began operation in 2010.
The review of the HI-STORM 100 Cask System was based on NRC-issued CoC No.
1014, Amendment 13 (CoC 1014-13) and its associated Safety Evaluation Report (SER),and HI-STORM 100 Final Safety Analysis Report (FSAR) Revision 18. The review of the Part 50 facility site-specific parameters utilized the Updated Final Safety Analysis Report (UFSAR) and other applicable plant-specific design and licensing basis information.
Observations and Findings - Review of 10 CFR 72.212 Evaluations
The inspectors evaluated the licensees compliance with the requirements of 10 CFR 72.212. The inspectors verified Exelons written evaluations were in accordance with 10 CFR 72.212(b)(5) and confirmed the conditions set forth in the CoC had been met prior to use and the radiological requirements of 72.104 had been met. The inspectors verified that applicable reactor site parameters, such as hypothetical fire and explosions, tornadoes, wind-generated missile impacts, seismic qualifications, lightning, flooding and temperature, had been evaluated for acceptability with bounding values specified in the FSAR and the NRC SER. The inspectors also verified that 50.59 evaluations related to the construction and operation of the ISFSI and plant interfaces were performed and that changes to certain facility design bases and UFSAR commitments did not require NRC approval. The reactor emergency plan, quality assurance program, training program, and radiation protection program were reviewed to verify that there was no decrease in effectiveness and no changes were made that required prior NRC approval.
The Ginna ISFSI pad was designed to accommodate TN-32T casks stored in type 102 horizontal storage modules (HSMs). At the time of this inspection, ten casks were stored in NUHOMS HSMs and placed on the Ginna ISFSI pad. Exelon plans to load up to 24 HI-STORM 100S Version B overpacks alongside the existing HSMs. The inspectors reviewed the evaluations to ensure a demonstration of reasonable assurance that the ISFSI pad at Ginna 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 review for static and dynamic loads associated with the new casks, as required by 10 CFR 72.212. In addition, the inspectors reviewed the site-specific tip over analysis of the HI-STORM 100S Version B and the soil structure interaction analysis performed for Ginna. 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 Ginna ISFSI pad was consistent with the HI-STORM FSAR as well as applicable guidance in American Concrete Institute 318-02, NUREG-1536 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.
No findings of significance were identified.
2.0 Exit Meeting
On December 11, 2020, the inspectors presented the inspection results to Mr. Paul Swift, 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
P. Swift
Site Vice-President
M. Cazzolli
Senior Manager Dry Cask Storage
J. DiBiase
Senior Manager Site Project Management
J. Gratton
Project Manager (contractor)
J. Fischer
Senior Regulatory Engineer
E. Hrbac
Project Manager (contractor)
M. Lavery
Dry Cask Storage Specialist
J. Reid
Dry Cask Storage Project Manager
ITEMS OPENED, CLOSED, AND DISCUSSED
None
LIST OF DOCUMENTS REVIEWED
Section 1.1 Review of 10 CFR 72.212 (b) Evaluations
CFR 50.59 and 10 CFR 72.48 Screenings/Evaluations
B-2019-036
B-2020-002
C-2020-001
Calculations
CALC-2020-0005; Ginna Cask Loader Cask Model Updates for 2020 ISFSI Campaign;
Revision 0
HI-2188381; Site Specific Tipover Analysis of HI-STORM 100S Version B; Revision 5
HI-2188459; Seismic Analysis of Hanging HI-TRAC; Revision 5
HI-2188403; Evaluation of Plant Hazards at R.E. Ginna NPP; Revision 4
HI-2188599; HI-STORM 100S Version B ISFSI Site Boundary and Dose vs Distance Calculation for
R.E. Ginna Nuclear Power Plant; Revision 1
HI-2188600; HI-STORM 100S Version B CoC Radiation Protection Program Dose Rate Limits for
R.E. Ginna NPP; Revision 1
HI-2188223; Thermal Evaluation of HI-STORM 100 System in the CTP at RE Ginna; Revision 1
HI-2188232; Effect of Cask Spacing on Thermal Performance of HI-STORM 100 System at Ginna;
Revision 1
HI-2188302; Thermal Analysis of HI-TRAC Onsite Transfer in Horizontal Orientation; Revision 3
HI-2188257; Cask Handling Weights at R.E. Ginna; Revision 4
HI-2188428; Seismic Analysis of VCT Carrying HI-TRAC and HI-STORM at Ginna; Revision 3
HI-2188476; Ginna Haul Path and Underground Utility Evaluation; Revision 2
HI-2188554; Structural Evaluation of Canister Preparation Bay Slab; Revision 1
HI-2188417; Seismic Stability Analysis of HI-TRAC in Cask Loading Area (CLA) and Structural
Qualification of Cask Pedestal, SFP Liner and Floor Slab; Revision 2
HI-2188461; Seismic Stability Analysis of HI-TRAC in Canister Preparation Building; Revision 2
HI-2188475; Evaluation of HI-PORT and VCT Fires on HI-STORM and HI-TRAC at Ginna; Revision 3
HI-2135647; Structural Qualification of 415 Kip VCT; Revision 4
HI-2135653; Generic VCT Seismic Technical Summary; Revision 5
Calculations (Contd)
HI-2146258; VCT Stability Analysis on Haul Path and ISFSI Pad for Multiple Nuclear Power Plants;
Revision 7
HI-2188458; Structural Qualification of HI-TRAC Transfer Skid and Missile Shield; Revision 3
HI-2188381, Site Specific Tip-over Analysis of HI-STORM 100S Version B, Revision 5
HI-2188388, Soil Structure Interaction Analysis of
- R.E. Ginna ISFSI Pad, Revision 3
HI-2188500, Structural Analysis of
- R.E. Ginna ISFSI Pad, Revision 3
Miscellaneous
CFR 72.212 Evaluation Report for the HI-STORM 100 System; Revision 0
50.54(q) Program Evaluation/Assessment Review Evaluation No.: 20-59; Emergency Action
Levels for Ginna Station,
AR 04371808; JLG Combustibles Not Included in HI-2188475 Rev. 3; dated 09/24/2020
CR 2847105H-10; After machining indications were observed in Weld 5-1; Revision 1
DOC-1026-012; HI-TRAC 100G for Ginna Nuclear Power Plant; Revision 0
DOC-1027-208-570; MPC Lid Lift Sling Assembly for Ginna; Revision 0
DOC-1027-209-562; (1)set MPC Lift Cleats for Ginna Nuclear Power Plant; Revision 0
DOC-1027-224-568; Mating Device for HI-STORM 100S Ver. B / HI-TRAC 100G for Ginna; Revision
DOC-1027-603-566; MPC 32 Upper Fuel Spacers for Exelon - R.E. Ginna Nuclear Power Plant;
Revision 0
DOC-1027-603-567; MPC 32 Lower Fuel Spacers for Exelon - R.E. Ginna Nuclear Power Plant;
Revision 0
DOC-1027-701-565; (Leased) HI-TRAC 100G Lift Links for Ginna Nuclear Power Plant; Revision 0
DOC-2847-004; HI-TRAC 100G Transfer Skid for Ginna; Revision 1
Documentation Package, J&R Project #1702; Holtec Vertical Cask Transporter 415; dated May 31,
2018
ECP-18-000273; Dry Storage Transition Project - Licensing & Operations; Revision 0
ECP-18-000439; Canister Transfer Pit; Revision 1
ECP-18-000440; Temperature Monitoring System; Revision 0
Holtec International Final Safety Analysis Report for the HI-STORM 100 Cask System;
Revision 18
N-AN-OU-HOL-OVERVIEW; HOLTEC DCS System Overview; Revision 0
PS-1120; Purchase Specification for the Vertical Cask Transporter; Revision 9
R.E. Ginna Nuclear Power Plant 10 CFR 72.212 Evaluation Report; Revision 3
R.E. Ginna Nuclear Power Plant UFSAR; Revision 28
Holtec Surveillance Report S2016-07; VCT415-4 Load Test; dated February 2, 2016
Procedures
EP-AA-1012 Addendum 3; Emergency Action Levels for Ginna Station; Revision 7
HPP-2847-200; MPC Loading; Revision 2
HPP-2847-300; MPC Sealing, Drying, and Backfilling; Revision 4
HPP-2847-0400; HI-TRAC Transfer, Stack-up, and MPC Download; Revision 1
HPP-2847-0500; HI-STORM Movements; Revision 1
HPP-2847-0700; Response to Abnormal Conditions; Revision 0
HSP-720; Inspection & Maintenance for Vertical Cask Transporter (VCT); Revision 2
HSP-34; Training of Site Services Personnel; Revision 19
LS-AA-114; Exelon 72.48 Review Process; Revision 1
RP-AA-305; Holtec HI-TRAC Radiation Survey; Revision 4
RP-AA-306; Holtec HI-STORM Radiation Survey; Revision 2
LIST OF ACRONYMS USED
Certificate of Compliance
CFR
Code of Federal Regulations
Cask Transfer Pit
Final Safety Analysis Report
HSM
Horizontal Storage Module
Independent Spent Fuel Storage Installation
Multipurpose Canister
NRC
U.S. Nuclear Regulatory Commission
Safety Evaluation Report
SPMT
Self Propelled Motorized Transporter
TS
Technical Specifications