L-2013-273, CFR 71.95 Report on the 8-120B Cask
| ML13283A006 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 09/30/2013 |
| From: | Jensen J Florida Power & Light Co |
| To: | Mark Lombard Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| L-2013-273 | |
| Download: ML13283A006 (7) | |
Text
0 September 30, 2013 FPL.
L-2013-273 10 CFR 71.95 Mr. Mark Lombard, Director Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington DC 20555-0001 ATTN: Document Control Desk Re:
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 10 CFR 71.95 Report on the 8-120B Cask
Reference:
- 1.
EnergySolutions letter to NRC dated August 14, 2013, "10 CFR 71.95 Report on the 8-120B Cask" Accession Number ML13247A179
Dear Mr. Lombard:
By Reference 1, EnergySolutions provided a report to NRC providing information required by 10 CFR 71.95(a)(3) related to the 8-120B cask (Certificate of Compliance
- 9168). The EnergySolutions report noted specific instances in which the Certificate of Compliance may not have been observed in making certain cask shipments. The circumstances described in the report were applicable to all licensed users of the cask.
The purpose of this letter is to notify NRC that Florida Power & Light (FPL) is a licensed user of this cask and to provide a copy of EnergySolutions report, as they are the certificate holder for the 8-120B cask.
FPL was notified of this condition in June and July 2013 by EnergySolutions.
Specifically, a discrepancy existed between the air pressure drop test procedure (TR-TP-002) and the 8-120B Safety Analysis Report (SAR) regarding the hold time for the pre-shipment leak test of the cask vent port. In keeping with 10 CFR 71.95(a), FPL needed the certificate holder's input in order to have the necessary information to meet the 10 CFR 71.95 reporting requirements. This input was provided to FPL by EnergySolutions on August 14, 2013, at the time the NRC was notified.
Even though NRC received the EnergySolutions report of August 14, 2013, FPL has attached the report in order to meet the reporting requirements of 10 CFR 71.95. During the timeframe over which the discrepancy between the air pressure drop test procedure and the 8-120B SAR has existed, FPL determined that two previous shipments have occurred at the St. Lucie Plant where we tested the subject cask vent port and performed the leak test using the incorrect hold time. The test procedures for cask shipments05-129 and 06-11, leaving the St. Lucie Plant on December 15, 2005 and Florida Power & Light Company U
6501 S. Ocean Drive, Jensen Beach, FL 34957
L-2013-273 Page 2 March 7, 2006, respectively, did not include the required hold times. The shipments were completed without any issues. As concluded in EnergySolutions report, there is no safety significance associated with this condition.
Any future shipments conducted by FPL using the 8-120B cask will be made using the revised procedure which includes the correct pressure drop hold time. In addition, the EnergySolutions report noted that beginning September 1, 2013, the 8-120B cask will ship with a new lid design. When the new cask lids are deployed, EnergySolutions notes that new procedures will be used consistent with the test requirements for these new lids.
If you have any questions related to this submittal, please contact Eric Katzman, St.
Lucie Licensing Manager at (772) 467-7734.
Respectfully submitted, roseph Jensen Site Vice President St. Lucie Plant JJ/KWF
Attachment:
EnergySolutions letter to NRC dated August 14, 2013, "10 CFR 71.95 Report on the 8-120B Cask"
L-2013-273 Attachment Page 1 of 5 ENERGYSOLUTIONS August 14, 2013 CD! 3-0232 Mark Lombard, Director Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington DC 20555-0001 ATTN: Document Control Desk
Subject:
10 CFR 71.95 Report on the 8-120B Cask
Dear Mr. Lombard:
EnergySolufions hereby submits the attached report providing the information required by 10 CFR 71.95(a)(3) for instances in which the conditions of approval in the Certificate of Compliance for the 8-120B Cask (Certificate of Compliance 49168) may not have been observed in making certain shipments. The circumstances described in this report are applicable to all licensed users of the cask.
If you have any questions regarding this submittal, please contact me at 801-649-2109.
Since Daniel B. Shrum Senior Vice President, Regulatory Affairs EnergySolutions
Attachment:
Failure to Observe Certificate of Compliance Conditions for the 8-120B Vent Port Leak Test Hold Time cc: Michele Sampson, Chief Thermal and Containment Branch Pierre M. Saverot Licensing Branch 423 West 300 South. Suite 200
- Satt Lake City. UT 84101 www.energysolutions.com
L-2013-273 Attachment Page 2 of 5 ENERGYSOLUT/O Failure to Observe Certificate of Compliance Conditions for the 8-120B Vent Port Leak Test Hold Time August 14, 2013 I) Abstract This report provides the information required by 10 CFR 71.95(a)(3) for instances in which the conditions of approval in the Certificate of Compliance for the 8-120B Cask (Certificate of Compliance #9168) may not have been observed in making certain shipments. The circumstances described in this report are applicable to all licensed users of the cask.
EnergySolutions' air pressure drop test procedure TR-TP-002 describes a 20-minute hold time for the pre-shipment leak test of the cask vent port. The 8-120B Safety Analysis Report (SAR), however, specifies a hold time of 60 minutes for the leak test of the vent port, therefore the conditions of approval in the Certificate of Compliance may not necessarily have been observed in making shipments. TR-TP-002 is the basis for leak tests on all EnergySolutions shipments, as well as the suggested procedure content for most shipments by our authorized users.1 The 8-120B CoC requires the package to be prepared for shipment and operated in accordance with Chapter 7 of the SAR, and tested and maintained in accordance with Chapter 8 of the SAR. TR-TP-002 captures the applicable SAR requirements and provides further detail for the development of a shipper's operating procedure. Recently, an 8-120B cask user identified the hold time discrepancy between TR-TP-002 and the SAR (i.e., 20 versus 60 minutes). Based on a review of past revisions of CoCs, SARs, and cask handling procedures, it appears that this discrepancy has existed for approximately 12 years, spanning approximately 88 cask users and approximately 1,400 shipments.
Upon notification and after confirmation of the discrepancy, EnergySolurions revised TR-TP-002 to incorporate die SAR required 60-minute vent port leak test. This change to TR-TP-002 was communicated to all EnergySolutions registered cask users on June 13, 2013. The SAR requires pre-shipment leak testing of the vent port only when the port has been opened since the preceding vent port leak test. EnergySolutions issued a notice to registered cask users on July 2, 2013 to clarify this issue. Operation of a package vent port is infrequent. However some vent ports may have been opened during the past 12 years; and therefore the pre-shipment leak testing would have been required.
The licensing basis for the pre-shipment leak tests for all three of the 8-120B lid containment seals is a pressure drop calculation forthe largest of the three seals (the primary lid seal).
The required hold time is therefore conservative for the two seals with smaller test volumes.
Because of the small size of the vent port seal test volume, EnergySolutons has determined that the 20-minute hold time meets the same criterion by which the 60-minute hold time was derived for the larger primary lid seal. In fact, in the case of the vent port leak test, the 20-minute hold time provides substantial margin for detecting any leakage from the vent port. It therefore follows that there is no safety significance associated with the condition.
Since registered users of the 8-120B package are licensees, these licensees would normally prepare and issue an approved procedure to control their pre-shipment activities.
L-2013-273 Attachment Page 3 of 5 ENERGYSOLUTIONS Furthermore, there is no continuing safety concern as new lids are required to be used after August 31, 2013 with different testing procedures.
Due to the long timeframe over which this condition has existed, the large number of 8-120B cask users, the many shipments that have occurred, the difficulty of determining which if any shipments may have been out of compliance, and the finding of no significant safety impact, EnergySolutions hereby submits this notification to summarize the issue as it applies to all 8-120B users. Because of the imminent rollout of new lids and related test procedures, no further corrective actions by certificate users are necessary to address this leak test procedure.
- 2) Narrative Description of the Event a) Status of Components All 8-120B components are operating normally.
b) Dates of Occurrences February 2001 to present.
c) Cause of Error Discrepancy between EnergySolutions air pressure drop test procedure TR-TP-002 and Chapter 8 of the 8-120B SAR.
d) Failure Mode, Mechanism, and Effects Not applicable; no 8-120B packaging components have failed.
e) Systems or Secondary Functions Affected Not applicable.
f) Method of Discovery of the Error The condition was identified by an 8-120B cask user.
- 3) Assessment of Safety Consequences There is no safety consequence of performing the pre-shipment leak test of the 8-120B cask vent port using a 20-minute hold time versus the 60-minute hold time that is required by the 8-120B CoC. The required hold time varies in proportion to the test volume if the test pressure and acceptance criterion remain unchanged. Larger test volumes require longer hold times. The test volume includes the free volume of the space to be tested and the volume of the test manifold. For the original subject 8-120B lids, Section 4.4 of the July 2012 SAR Addendum shows the calculation basis for a 60-minute hold time. Only one calculation was presented for the large primary lid containment seal. Since the other seals have smaller test volumes, a 60-minute hold time was conservatively specified for all seals, including the vent port.
L-2013-273 Attachment Page 4 of 5 ENERGYSOLUTIONS The SAR test volume for the primary containment seal was 103.2 cc. For the pre-shipment vent port leak test, there is no safety impact from a 20-minute hold time provided that the test volume is less than or equal to the 20/60 times the primary containment seal test chamber volume, or (20/60)* 103.2 = 34.4 cc. The vent port test volume is equal to the combined volume of the test manifold (10 cc) plus a very small residual volume inside the vent port, which is less than 34.4 cc. Therefore, pre-shipment leak tests of the vent port performed using a 20-minute hold time are adequate to demonstrate compliance with maximum leak rate acceptance criteria, and there is no safety consequence from testing vent ports for 20 minutes instead of 60 minutes.
- 4) Planned Corrective Actions As noted above, upon notification and after confirmation of the discrepancy, EnergySolutions revised TR-TP-002 to incorporate the SAR required 60-minute vent port leak test and notified registered cask users of the change.
Beginning September 1,2013, the 8-120B fleet will ship with a new lid design, authorized in the latest revision of the CoC.G Thereafter, the 8-120B cask may no longer be used with the old seals that were authorized in Revision No. 17 of the 8-120B CoC. Shipments with the new lids will be required to use the seals authorized in Revision 19 of the CoC. The EnergySolutions air pressure drop test procedure TR-TP-002 is being revised and reissued based on the requirements of Revision 19 of the 8-1 20B CoC. These revisions are reviewed and approved by the EnergySolutions Cask Licensing Manager to assure that they are compliant with the requirements of the CoC.
EnergySolutions also has initiated a lifecycle procedure for managing Type B casks to assure that CoC requirements flow through the design, fabrication, and operational phases. This is a new procedure that also would identify existing inconsistencies and prevent future inconsistencies between the SAR and operating procedures. The procedure will be effective August 19, 2013.
The error in incorporating the revised 60-minute vent port leak rate criteria into TR-TP-002 raises a question as to whether there are other similar errors involving the flow-down of requirements into operating procedures. Accordingly, EnergySolutions plans to conduct a review of the 8-120B and other EnergySolutions Type B packagings to verify that CoC and SAR requirements have been accurately translated into the prescribed operating procedures.
If any such discrepancies are found, EnergySolutions will expand the scope of these reviews as necessary.
- 5) Previous Similar Events Involving the 8-120B No previous similar events have been identified.
2 No shipments have been made using the new lids to date.
L-2013-273 Attachment Page 5 of 5 ENERGYSOLUTiONS
- 6) Contact for Additional Information Dan Shrum EnergySolutions Senior Vice President, Regulatory Affairs (801) 649-2109
- 7) Extent of Exposure of Individuals to Radiation or Radioactive Materials None.