ML081690841

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IR 05000397-08-007; 07200035-08-001 on 04/14/08 - 05/19/08 for Columbia Generating Station and Notice of Violation
ML081690841
Person / Time
Site: Columbia  Energy Northwest icon.png
Issue date: 06/17/2008
From: Spitzberg D
Division of Nuclear Materials Safety IV
To: Parrish J
Energy Northwest
References
EA-08-183 IR-08-007
Download: ML081690841 (21)


See also: IR 05000397/2008007

Text

June 17, 2008

EA-08-183

J. V. Parrish

Chief Executive Officer

Energy Northwest

P.O. Box 968 (Mail Drop 1023)

Richland, Washington 99352-0968

SUBJECT:

INSPECTION REPORT NOS 050-397/08-007; 072-035/08-001 AND

NOTICE OF VIOLATION

Dear Mr. Parrish:

This refers to the inspection conducted from April 14 through May 19, 2008, at the Columbia

Generating Station. The purpose of the initial onsite inspection conducted April 14-17, 2008, was

to perform a routine operational inspection of the Independent Spent Fuel Storage Installation

(ISFSI) and to follow up on the hydrogen burn event that occurred during canister closure welding

operations on April 8, 2008. Following implementation of corrective actions designed to prevent

recurrence, a second hydrogen burn event occurred during the inspection on April 16, 2008.

Your staff determined that the best course of action was to secure the canister in a safe

configuration and bring in outside industry resources to determine the cause(s) of the hydrogen

burn events and implement additional actions to prevent recurrence. A debrief was conducted

with members of your staff on April 17, 2008. The inspection remained open as your staff

conducted a Technical Issues Resolution Process to determine the cause of the hydrogen burn

events and actions to prevent recurrence. Following changes to your welding process, the

Resident Inspector observed the welding operations on canister serial numbers 169 and 170,

which occurred without further incident on April 26 and May 1, 2008, respectively. A telephonic

exit was conducted with Mr. Tom Lynch and other members of your staff on May19, 2008. The

enclosed report presents the results of the inspection.

This inspection was an examination of activities conducted under your license as they relate to

safety and compliance with the Commissions rules and regulations and with the conditions of

your license. Within these areas, the inspection included reviews of the hydrogen burn events,

selected examination of procedures and representative records, observations of activities, and

interviews with selected personnel.

Based on the results of the inspection, the NRC has determined that a Severity Level IV violation

of NRC requirements occurred. The violation was evaluated in accordance with the NRC

Enforcement Policy included on the NRCs website at www.nrc.gov/about-

nrc/regulatory/enforcement/enforce-pol.html.

UNITED STATES

NUCLEAR REGULATORY COMMISSION

R E GI ON I V

612 EAST LAMAR BLVD, SUITE 400

ARLINGTON, TEXAS 76011-4125

Energy Northwest

- 2 -

EA-08-183

The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances

surrounding it are described in detail in the subject inspection report. Consistent with Section VI.A

of the Enforcement policy, the violation is being cited in the Notice because the licensee failed to

restore compliance within a reasonable time after a noncompliance was identified.

In addition, the NRC has determined that one additional Severity Level IV violation of NRC

requirements occurred. This violation is being treated as a Non-Cited Violation (NCV),

consistent with Section VI.A of the Enforcement policy. The NCV is described in the subject

inspection report.

You are required to respond to this letter, as it pertains to the Notice described above, and should

follow the instructions specified in the enclosed Notice when preparing your response.

In addition, if you contest the violation or 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 Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with

copies to: the Regional Administrator, NRC Region IV; the Director, Office of Enforcement,

United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and Mr. Zachary

Dunham, Senior Resident Inspector at Columbia Generating Station. The NRC will use your

response, in part, to determine whether further enforcement action is necessary to ensure

compliance with regulatory requirements.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its

enclosures, and your response will be available electronically for public inspection in the NRC

Public Document Room or from the NRC's document system (ADAMS). ADAMS is 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.

Sincerely,

/RA/

D. Blair Spitzberg, Ph.D., Chief

Repository and Spent Fuel Safety Branch

Docket: 50-397

License: NPF-21

Enclosures:

1. Notice of Violation

2. NRC Inspection Report 050-0397/08-007; 072-0035/08-001

w/Attachments

Energy Northwest

- 3 -

EA-08-183

cc: w/enclosures

Chairman

Energy Facility Site Evaluation Council

P.O. Box 43172

Olympia, WA 98504-3172

Gregory V. Cullen

Manager, Regulatory Programs

Energy Northwest

P.O. Box 968, Mail Drop PE20

Richland, WA 99352-0968

Chairman

Benton County Board of Commissioners

P.O. Box 190

Prosser, WA 99350-0190

William A. Horin, Esq.

Winston & Strawn

1700 K Street, NW

Washington, DC 20006-3817

Matt Steuerwalt

Executive Policy Division

Office of the Governor

P.O. Box 43113

Olympia, WA 98504-3113

Lynn Albin

Washington State Department of Health

P.O. Box 7827

Olympia, WA 98504-7827

Technical Services Branch Chief

FEMA Region X

130 228th Street S.W.

Bothell, WA 98201-9796

Ken Niles

Assistant Director

Nuclear Safety and Energy Siting Division

Oregon Department of Energy

625 Marion Street NE

Salem, OR 97301-3742

Energy Northwest

- 4 -

EA-08-183

Special Hazards Program Manager

Washington Emergency Management Division

127 W. Clark Street

Pasco, WA 99301

Mike Hammond

Department of Homeland Security

FEMA/REP

130 228th Street S.W.

Bothell, WA 98201-9796

Energy Northwest

- 5 -

EA-08-183

DISTRIBUTION:

Regional Administrator (Elmo.Collins@nrc.gov)

DRA (Chuck.Casto@nrc.gov)

RC/ACES TL (Karla.Fuller@nrc.gov)

SES (Michael.Vasquez@nrc.gov)

DNMS Director (Art.Howell@nrc.gov)

DRP Director (Dwight.Chamberlain@nrc.gov)

DRS Director (Roy.Caniano@nrg.gov)

Senior Resident Inspector (Zachary.Dunham@nrc.gov)

Resident Inspector (Ronald.Cohen@nrc.gov)

Branch Chief, DRP/A (Claude.Johnson@nrc.gov)

RSFS Inspector (Ray.Kellar@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

SFST Senior Inspector (Robert.Temps@nrc.gov)

SFST Senior Project Manager (Randy.Hall@nrc.gov)

Columbia Site Secretary (Crystal.Myers@nrc.gov)

Alexander.Sapountzis@nrc.gov

Nick.Hilton@nrc.gov

ROPreports

SUNSI Review Completed: RLK ADAMS: Yes

No Initials: RLK

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

S:\\DNMS\\!FCDB\\!RLK\\CGS72-0801RLK.doc

RIV:DNMS/RSFS

DRP/

NMSS/SFST SFST

ACES

D:DNMS

C:RSFS

RLKellar

RBCohen

JRHall

RTemps

GMVasquez ATHowell

DBSpitzberg

/RA/

E-VJEverett

E-RLKellar

E-RLKellar

E-RLKellar /RA/

/RA/

6/16/08

6/10/08

6/16/08

6/16/08

6/16/08

6/17/08

6/16/08

OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

Enclosure 1

NOTICE OF VIOLATION

Energy Northwest

Docket Nos. 050-00397; 072-00035

Columbia Generating Station

License No. NPF-21

EA-08-183

During an NRC inspection conducted from April 14 through May 19, 2008, a violation of NRC

requirements was identified. In accordance with the NRC Enforcement Policy, the violation is

listed below:

10 CFR 72.210 provides, in part, a general license for the storage of spent fuel in an

independent spent fuel storage installation (ISFSI) at power reactor sites, to persons

authorized to operate nuclear power reactors under 10 CFR Part 50. This general

license is limited to storage of spent fuel in casks approved under the provisions of

10 CFR Part 72.

Certificate of Compliance (CoC) 1014, for the HI-STORM Cask System was issued in

accordance with 10 CFR 72.238. The certificate states, in part, that it is conditional upon

fulfilling the requirements of 10 CFR Part 72, as applicable, and the attached Appendix A

(Technical Specification) and Appendix B (Approved Contents and Design Features).

Section 3.8 of CoC 1014, Appendix B, requires, in part, that during the Multi-Purpose

Canister (MPC) lid-to-shell welding operations, combustible gas monitoring of the space

under the MPC lid be performed to ensure that no combustible gas mixture is present in

the welding area.

Contrary to the above, on April 8, 2008, and again on April 16, 2008 the licensee did not

effectively monitor combustible gas concentrations under the MPC lid during the MPC

lid-to-shell welding operations to ensure that no combustible gas mixture was present in

the welding area. Specifically, on April 8, 2008, after the root pass of the lid-to-shell weld

had been completed and work was being done on the next weld layer, the licensee

elected to suspend combustible gas concentration monitoring; and on April 16, 2008, the

position of the licensees explosive gas monitor relative to the MPC vent port did not

effectively detect combustible gas concentrations. Both of these situations resulted in

hydrogen burn events.

This is a Severity Level IV violation (Supplement VI).

Pursuant to the provisions of 10 CFR 2.201, Energy Northwest is hereby required to submit a

written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document

Control Desk, Washington, DC 20555-0001 with a copy to the Regional Administrator,

Region IV, and a copy to the NRC Resident Inspector at the facility that is the subject of this

Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This

reply should be clearly marked as a "Reply to a Notice of Violation; EA-08-183," and should

include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing

the violation or severity level, (2) the corrective steps that have been taken and the results

achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date

when full compliance will be achieved. Your response may reference or include previous

docketed correspondence, if the correspondence adequately addresses the required response.

Enclosure 1

- 2 -

If an adequate reply is not received within the time specified in this Notice, an order or a Demand

for Information may be issued as to why the license should not be modified, suspended, or

revoked, or why such other action as may be proper should not be taken. Where good cause is

shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response, with the

basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory

Commission, Washington, DC 20555-0001.

Because your response will be made available electronically for public inspection in the NRC

Public Document Room or from the NRCs document system (ADAMS), accessible from the NRC

Web site at www.nrc.gov/reading-rm/pdr.html or www.nrc.gov/reading-rm/adams.html, to the

extent possible, it should not include any personal privacy, proprietary, or safeguards information

so that it can be made available to the public without redaction. If personal privacy or proprietary

information is necessary to provide an acceptable response, then please provide a bracketed

copy of your response that identifies the information that should be protected and a redacted

copy of your response that deletes such information. If you request withholding of such material,

you must specifically identify the portions of your response that you seek to have withheld and

provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of

information will create an unwarranted invasion of personal privacy or provide the information

required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or

financial information). If safeguards information is necessary to provide an acceptable response,

please provide the level of protection described in 10 CFR 73.21.

In accordance with 10 CFR 19.11, you may be required to post this Notice within two working

days.

Dated this 17th day of June 2008

Enclosure 2

- 1 -

ENCLOSURE

U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket Nos:

050-00397; 072-00035

License No.:

NPF-21

Report Nos.:

050-0397/08-007; 072-0035/08-001

Licensee:

Energy Northwest

Facility:

Columbia Generating Station

Location:

Richland, Washington

Dates:

April 14 through May 19, 2008

Inspectors:

Ray Kellar, P.E., ISFSI Inspector, Repository and Spent Fuel Safety Branch

Ron Cohen, Resident Inspector, Projects Branch A

Approved By:

D. Blair Spitzberg, Ph.D, Chief

Repository and Spent Fuel Safety Branch

Attachments:

Supplemental Information

Loaded HI-STORM 100S Casks at the Columbia Generating Station ISFSI

Enclosure 2

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EXECUTIVE SUMMARY

Columbia Generating Station

NRC Inspection Report Nos. 050-0397/08-007; 072-0035/08-001

An inspection of the Columbia Generating Station (CGS) Independent Spent Fuel Storage

Installation (ISFSI) facility in Richland, Washington was conducted from April 14, 2008 through

May 19, 2008. A routine operational inspection of ISFISI activities was conducted to verify that

the ISFSI was being maintained in compliance with the applicable requirements of the Certificate

of Compliance (CoC), Final Safety Analysis Report (FSAR), and 10 CFR Part 72. Additionally, a

follow up inspection of the hydrogen burn event that had occurred during the welding operations

on April 8, 2008, was arranged. A second hydrogen burn event occurred on April 16, 2008,

during the routine operational inspection. The licensee determined that the best course of action

was to secure the canister in a safe configuration and bring in outside industry resources to

determine the cause(s) of the hydrogen burn events and implement actions to prevent

recurrence. A debrief was conducted with the licensee on April 17, 2008. The inspection

remained open as the licensee conducted a Technical Issues Resolution Process to determine

the cause of the hydrogen burn events and actions to prevent recurrence. Following changes to

the welding process, the Resident Inspector observed the welding operations on canister serial

numbers 169 and 170, which occurred without further incident on April 26 and May 1, 2008,

respectively.

Operation of an ISFSI (60855.1)

Two hydrogen burn events occurred during welding of the MPC lid-to-shell welds on

canister serial numbers 168 and 169. During the welding operations for canister serial

number 168 the licensee elected to suspend combustible gas monitoring after the

completion of the root pass weld. A hydrogen ignition event occurred on this canister

after the suspension of the combustible gas monitoring. Following this event the licensee

implemented procedure changes to require combustible gas monitoring during the entire

MPC lid-to-shell weld process. Despite this and other corrective actions, the combustible

gas monitoring configuration was ineffective in determining the presence of combustible

gases and a second hydrogen burn event occurred during welding operations on the next

canister loaded, MPC canister serial number 169. Following the second hydrogen burn

event, the licensee placed the MPC in a safe configuration and brought in individuals with

outside industry experience to determine the causes of the hydrogen burn events and

determine corrective actions to prevent recurrence. The licensee implemented changes

to introduce an inert gas (argon) beneath the MPC lid during the lid-to-shell welding

process and to relocate the explosive gas monitor sampling point to the vicinity of the

MPC vent port. The completion of the MPC lid-to-shell weld on canister serial

numbers 169 and 170 occurred without further incident. A Notice of Violation is being

issued, consistent with Section VI.A.1 of the NRC Enforcement Policy for failure to

monitor combustible gas concentrations during the MPC lid-to-shell weld. (Section 1.2.a)

The licensee procedures contained sufficient information to select and load spent fuel

assemblies into storage in compliance with CoC, Appendix B requirements. Selected fuel

assemblies were verified by the inspector to meet the CoC, Appendix B requirements.

(Section 1.2.b)

Enclosure 1

- 3 -

The licensee was performing radiological surveys of canister contamination and cask

dose rates in accordance with the Technical Specification requirements. Result of

surveys performed for selected canisters and casks were well below the Technical

Specification limits. (Section 1.2.c)

The licensee was meeting the Technical Specification requirements for daily monitoring of

temperature readings of the cask outlet vents and ambient air. All of the selected daily

temperature readings reviewed were found to be below the Technical Specification and

licensee specified maximum temperature limits. (Section 1.2.d)

The ISFSI related condition reports sampled from the licensees corrective action system

adequately addressed the identified deficiencies and provided appropriate corrective

actions. (Section 1.2.e)

The licensee was meeting the requirements of 10 CFR 72.176 for conducting periodic

audits of the ISFSI program. Deficiencies discovered during the audits were entered into

the licensee corrective action program for evaluation, as appropriate. (Section 1.2.f)

72.48 Evaluations (60857)

The licensee 10 CFR 72.48 screenings and the single 10 CFR 72.48 evaluation had been

performed in accordance with the requirements of 10 CFR 72.48(c). However, the

licensee did not perform a 10 CFR 72.48(c) review of the changes to the written

evaluations contained in Section 1.1.2 of the Energy Northwest Independent Spent Fuel

Storage Installation 10 CFR 72.212 Evaluation, as required by 10 CFR 72.212(b)(2)(ii).

This violation is being treated as a Non-Cited Violation, consistent with Section VI.A.1 of

the NRC Enforcement Policy. (Section 2.2)

Follow-up (IP 92701)

Inspection Follow-up Item (IFI) 72-35/0401-01 associated with the review of

10 CFR 72.212(b) changes necessary to support the inclusion of the hydrogen water

chemistry project has been closed in this inspection report. The licensees analysis

indicated that the existing explosion hazards analysis, which considered the probability of

a projectile impacting the HI-STORM cask during transportation or storage, was not

altered by the inclusion of the hydrogen water chemistry project. (Section 3)

Enclosure 1

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REPORT DETAILS

Summary of Facility Status

Columbia Generating Station is a General Electric boiling water reactor owned by Energy

Northwest. The facility is located approximately 12 miles northwest of Richland, Washington, on

the Department of Energys Hanford Reservation. Energy Northwest selected the Holtec HI-

STORM 100S cask system for storage of their spent fuel. The licensee was loading spent fuel

under the general license requirements of Certificate of Compliance (CoC) 1014, Amendment 2.

The initial Independent Spent Fuel Installation (ISFSI) loading campaign was completed in

December 2002 and consisted of five casks. The second loading campaign was completed in

April of 2004 and consisted of ten casks. The third spent fuel loading campaign was in progress

at the time of the inspection and consisted of 12 additional casks. The inspectors witnessed

portions of the loading operations associated with Multi-Purpose Canister (MPC) serial

numbers 168 and 169 during the third loading campaign.

1

Operation of an ISFSI (60855.1)

1.1

Inspection Scope

An inspection of the Columbia Generating Station ISFSI was conducted to verify the

licensee was operating the ISFSI in conformance with the requirements of the CoC, the

Final Safety Analysis Report (FSAR) and 10 CFR Part 72. Portions of licensee activities

associated with fuel selection, radiological surveillances, heat removal surveillances,

corrective actions and Quality Assurance audits were reviewed during the inspection. The

inspection of the hydrogen burn events and corrective actions taken by the licensee were

also reviewed.

1.2

Observations and Findings

a.

Hydrogen Burn Events

The potential for a hydrogen burn to occur during canister closure welding operations was

first communicated by the NRC to licensees in 1996, using NRC Bulletin 96-04 and

Information Notice 96-34. Hydrogen can be produced during loading operations by

radiolysis of the water surrounding the loaded fuel assemblies and the passivation of the

aluminum neutron absorbers exposed to water in the canister. Once the canister cavity is

drained, dried, and backfilled with helium, the source of the hydrogen gas is eliminated.

A hydrogen burn event occurred at approximately 2:45 pm on April 8, 2008, during loading

operations for MPC serial number 168. The hydrogen burn event occurred during the

welding operations on the seventh canister that had been loaded with spent fuel during

the current CGS canister loading campaign. The root pass of the lid-to-shell weld had

been completed. The welders were working on the next weld layer using a hot wire pass

and had completed approximately one-half of the lid circumferential weld using two weld

heads when the first hydrogen burn event occurred. The hydrogen burn caused the vent

and drain port covers to be blown off the MPC lid and relocated several inches away.

Approximately a quart of water from the MPC drain port was ejected and deposited on the

MPC lid.

Enclosure 1

- 5 -

The licensee stopped the welding operations and placed the canister in a safe condition.

The licensee was using Procedure 6.6.7, MPC Processing, Revision 17 to control the

installation activities. The revision of Procedure 6.6.7 in use allowed the cask loading

supervisor to stop the venting and combustible gas monitoring after the root pass of the

lid-to-shell weld had been completed. Consistent with this procedure, the licensee had

stopped venting and monitoring of the combustible gas concentration after the root pass

weld had been completed. The licensee determined that a hydrogen burn event had

occurred during the lid-to-shell welding operations. After reestablishing the combustible

gas monitoring for explosive gas concentrations in the MPC, the licensee completed the

lid-to-shell weld for canister serial number 168 without further incident.

Section 3.8 of CoC 1014, Appendix B, Approved Contents and Design Features,

required in part that during the MPC lid-to-shell welding operations, combustible gas

monitoring of the space under the MPC lid be performed to ensure that no combustible

gas mixture is present in the welding area. Contrary to this requirement, on April 8, 2008,

the licensee process did not monitor combustible gas concentrations under the MPC lid

during the full duration of the MPC lid-to-shell welding operations of MPC serial number

168. This was identified as a violation of Section 3.8 of CoC 1014, Appendix B.

Following the hydrogen event on April 8, 2008, the licensee determined that the area

beneath the MPC lid needed to be continuously vented and monitored for explosive gases

during the welding of the lid-to-shell weld. The licensee implemented corrective actions in

Revision 19 to Procedure 6.6.7 to require continuous venting and combustible gas

monitoring during the lid-to-shell weld. A clear tygon hose was firmly attached to the

canister vent port and routed to a receiving tank. Another hose was routed from the

receiving tank to the inlet of the explosive gas monitor during the welding operations.

Following implementation of corrective actions from the first hydrogen burn event, a

second hydrogen burn event occurred on April 16, 2008, at approximately 11:58 pm,

during welding operations of the hot wire layer on MPC serial number 169. Similar to the

first hydrogen burn event, the root pass weld had been completed and the hot wire weld

layer pass was in process at the time of the event. The second hydrogen burn event

caused the tygon hose on the vent port and the drain port cover plate to be blown off and

water from the MPC drain line was deposited on the MPC lid.

The NRC inspector was informed of the second hydrogen burn event and arrived onsite at

approximately 2:00 am on April 17, 2008. The inspector observed that the explosive gas

monitor was in place and that the monitor indicated that no explosive gas was present.

The inspector questioned the CGS supervisor as to whether the existing configuration of

the explosive gas monitor would detect explosive gases and the supervisor took a spare

calibrated monitor to the MPC vent port to check for the presence of an explosive

atmosphere. The monitor read off scale high on explosive gases when exposed to the

MPC vent port. The supervisor then removed the explosive gas monitor that was

configured to detect the presence of explosive gases from the MPC vent port, which also

registered off scale high on explosive gases when exposed directly to the MPC vent port.

The licensee secured the MPC in a safe condition and proceeded to determine the next

course of action to be taken.

Enclosure 1

- 6 -

As previously stated, Section 3.8 of CoC 1014, Appendix B, required that during the MPC

lid-to-shell welding operations, combustible gas monitoring of the space under the MPC

lid was required to ensure that there was no combustible gas mixture present in the

welding area. Contrary, to the above requirement, on April 16, 2008, the licensee system

configuration did not effectively monitor combustible gas concentrations under the MPC

lid which contributed to a second hydrogen burn event. This is a violation of Section 3.8

of CoC 1014, Appendix B. This violation is being treated as a cited violation, consistent

with Section VI.A.1 of the NRC Enforcement Policy.

Following the second occurrence of a hydrogen burn, the licensee suspended loading

operations and commenced recirculation of water from the spent fuel pool through the

MPC. Individuals with outside industry experience arrived on site to assist in the

determination of the cause of the hydrogen burn events and determine the best method to

prevent recurrence. The team performed a root cause analysis utilizing change analysis

and barrier analysis methods. The Summary Report Hydrogen Burn Event was still in

draft form at the time this inspection report was prepared, however the licensee had

decided to introduce an inert gas (argon) beneath the MPC lid during the lid-to-shell

welding process to prevent recurrence. The licensee also relocated the explosive gas

monitor sampling point to the vicinity of the MPC vent port. As part of the licensees

corrective actions, Procedure 6.6.7 was revised to include directions on how to introduce

the inert gas into the MPC void area and how to monitor for explosive gases in

Attachment 9.14, Combustible Gas Monitoring and Purging, Revision 20.

An evaluation of the potential impact of the bounding hydrogen burn event on the spent

fuel assemblies and the spent fuel canister was performed by the dry fuel cask vendor.

The calculated pressure increase that occurred during the hydrogen burn event was

determined to be less than 1.0 psi, which is a small fraction of the normal design pressure

of the MPC (100 psi) or the spent fuel rods (in excess of 1,000 psi). Therefore, the

integrity of the MPC and the spent fuel assemblies was unaffected by the hydrogen burn

events.

On April 26, 2008 the inspectors witnessed the resumption of welding operations by

Energy Northwest personnel on MPC serial number 169. The inspectors reviewed the

revised hydrogen purge and monitoring process as part of the Procedure 6.6.7,

Revision 20. The inspectors observed the hydrogen purge gas setup and implementation

and the process used by the licensee to monitor for explosive gases during the welding

process. The inspectors concluded that the procedures had been adequately revised and

that the installation activities were completed without any recurrence of the of the previous

hydrogen burn events. Additionally, the inspectors made similar observations of the

welding operations on MPC serial number 170 on May 1, 2008 with the same

conclusions.

b.

Fuel Selection

The MPC-68 canister fuel parameters are specified in the Holtec CoC 1014, Appendix B,

Section 2.0, Approved Contents. The fuel assemblies that had been loaded into

canister serial numbers 162 (cask 16), 164 (cask 18) and 166 (cask 20) were selected for

review by the inspector and compared against the requirements located in the CoC.

Enclosure 1

- 7 -

The licensee utilized several procedures to document the fuel selection process, fuel

loading process and to provide verification that the fuel assemblies had been placed in

the correct canister cell location. Procedure 9.6.1, Spent Fuel Selection for Cask

Storage, Revision 2 had been used to select the fuel assemblies for loading during the

current cask campaign. Procedure 9.6.1 had been revised to include the fuel selection

requirements contained in CoC 1014, Amendment 2.

Procedure 9.6.1, Attachment 9.3, Cask Loading Plan, included locations for the preparer

and reviewer to document that the fuel assemblies selected for loading met the CoC

Appendix B requirements. The attachment also specified the MPC canister storage cell

where the fuel assembly was to be placed. The attachments for canister serial

numbers 162, 164 and 166 were reviewed by the inspector and were found to have been

signed by the preparer and reviewer as meeting the CoC Appendix B requirements.

Procedure 6.3.40, Determination of Fuel Assembly Condition for ISFSI, Revision 4,

provided the procedural guidance to ensure that selected fuel assemblies met the CoC

definition of intact fuel, consisting of no known or suspected cladding defects greater than

pinhole leaks or hairline cracks. The inspector reviewed the criteria contained in the

procedure as well as supplemental fuel sipping data contained in Calculation NE-02-00-

08, Revision 1, which documented which discharged spent fuel assemblies were suspect

and flagged as lacking documentation to meet the CoC definition of intact fuel. All of the

fuel assemblies from cycle 3 and 4 were suspect as well as four fuel assemblies from

cycle 5 and one fuel assembly from cycle 15. There were also 45 fuel assemblies that

were discharged from cycle 5 that were suspect. The inspector reviewed a sampling of

fuel assemblies to be loaded in canister serial numbers 162, 164 and 166 and determined

that the licensee had not selected any of the suspect fuel assemblies that lacked sufficient

documentation as meeting the definition of intact fuel for loading into the selected

canisters.

Procedure 6.6.15, Fuel Handling and Refuel Activities Procedures, Revision 5 was used

to verify that the fuel assembly that had been selected for placement by Procedure 9.6.1

had been placed in the correct MPC canister cell. Page 11 of Procedure 6.6.15 required

the signature of the preparer and reviewer that performed the verification of each fuel

assembly serial number by MPC cell location. The inspector reviewed the documentation

for canister serial numbers 162, 164 and 166 and determined that all assemblies had

been documented as being installed in the correct canister cell.

c.

Radiological Surveillances

The Holtec Technical Specifications included bounding requirements for levels of

contamination and radiological dose levels on the canisters and casks. The inspector

reviewed the licensee documentation of the dose rate surveys performed on selected

HI-STORM and of selected contamination level surveys performed on the HI-TRAC

transfer cask and the canisters.

Technical Specification 3.2.2 required the removable contamination on the exterior

surfaces of the transfer cask and the accessible portions of the canister not to exceed

1,000 disintegrations per minute (dpm) per 100 square centimeters from beta and gamma

sources and 20 dpm/100 square centimeters from alpha sources.

Enclosure 1

- 8 -

Procedure HSP-SFS-C102, Transfer Cask Surface Contamination, Revision 2 provided

directions for obtaining contamination surveys of the HI-TRAC transfer cask and the

accessible portions of the MPC. The contamination smears were counted for alpha and

beta-gamma contamination. The results for each MPC were recorded in Attachment 9.1.

The inspector reviewed the results of the contamination smears for canister serial

numbers 162, 164 and 166. All the documentation indicated that the smears were below

the required Technical Specification limits of 1,000 dpm/100 square centimeters from beta

and gamma sources and 20 dpm/100 square centimeters from alpha sources.

Technical Specification 5.7.8 required dose rates to be measured at the HI-STORM cask

inlet and outlet vent screens, on the cask top and on the sides of the cask. The measured

surface dose rates (gamma + neutron) were required to be below the licensees site-

specific surface dose rate limit. In the case of the cask top and sides, additional upper

limits were imposed of 20 mrem/hour for the cask top and 110 mrem/hour for the cask

sides.

The inspector reviewed the licensee documentation for the HI-STORM dose rate

measurements taken on the concrete casks containing canister serial numbers 162, 164,

and166. The HI-STORM surface dose rate measurements were documented in

Procedure HSP-SFS-C103, Overpack Average Surface Dose Rate, Revision 3. The

calculated site-specific HI-STORM dose rates for the sides, top and vent ducts were

included in Attachment 9.2, HI-STORM Surface Dose Rates Data Sheet. The measured

HI-STORM dose rates for canister serial numbers 162, 164 and 166 were all well below

the site-specific surface dose rate limits. Additionally, the site-specific dose rate limits for

the HI-STORM top and sides were well below the upper limits imposed by the Technical

Specifications of 20 mrem/hour and 110 mrem/hour, respectively.

d.

Heat Removal Surveillances

Holtec Technical Specification 3.1.2.1 required the licensee to either verify that all the

storage cask inlet and outlet air ducts were free from blockage every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or for

storage casks with installed temperature monitoring equipment, verify that the difference

between the average storage cask air outlet temperature and the ISFSI ambient

temperature was less than or equal to 126 degrees Fahrenheit every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The

licensee had elected to monitor the cask temperatures in lieu of inspecting the inlet and

outlet ducts.

The inspector selected the licensee cask temperature records for the months of July 2006

and December 2007 for review. Procedure OSP-SFS-D101, Spent Fuel Storage Cask

Heat Removal System Daily Checks, Revisions 6 through 9 had been used to document

the daily temperatures. The licensee had specified a more conservative cask outlet

temperature difference of 114 degrees Fahrenheit in Procedure OSP-SFS-D101. All of

the daily temperature readings from the selected months were reviewed and found to be

less than the licensee specified 114 degree Fahrenheit temperature difference between

the cask outlet vent temperatures and the ambient air temperatures.

Enclosure 1

- 9 -

e.

Corrective Actions

The licensee prepared a list of the ISFSI related condition reports that had been

generated since the last NRC inspection in April 2004. The inspector selected nine of the

condition reports for review. The condition reports reviewed by the inspector were:

Condition Report No.

Condition Report Description

21608

Smears should be taken before decontamination of casks

21673

MPC Lid would not fully seat into MPC

22279

Casks 8-15 do not have temperature monitoring

22377

In-process documents storage not meeting QA program

35087

OE-Hatch crawler found to have damaged lift towers

40558

Daily screen checks are performed outside of ISFSI fence

41190

Maintenance procedures require 10 CFR 72.48 screens

176686

Lack of procedural guidance for snow blocking ISFSI vents

179373

Lead snakes identified on MPC to be downloaded

The inspector determined that the corrective actions associated with the listed condition

reports and associated deficiencies appeared to have been appropriately addressed by

the licensee. No additional findings were identified.

f.

Quality Assurance Audits

Two Quality Assurance Audits of the ISFSI program had been performed by the licensee

since the last NRC inspection completed on March 31, 2004. Audit Report AU-DC-04,

documented the audit that had been conducted during the second cask loading campaign

from April 19 to May 13, 2004. Audit Report AU-DC-06 included observations that had

been conducted from April 6 to May 11, 2006. The audit teams had identified several

ISFSI program weaknesses and had initiated Condition Reports (CRs) and Problem

Evaluation Requests (PERs).

The inspector reviewed Procedure SWP-ASU-01, Evaluations of Programs, Processes,

and Suppliers, Revision 17 which provided instructions for conducting internal and

external audits to determine the effectiveness of the Columbia Generating Station Quality

Assurance Program. Attachment 7.1 listed the audit frequency of the ISFSI program as

discretionary. The inspector noted that 10 CFR 72.176 required in part that the licensee

shall carry out a comprehensive system of planned and periodic audits to verify

compliance with all aspects of the quality assurance program. The licensee had been

conducting audits on a biennial frequency which met the requirement of 10 CFR 72.176,

however Procedure SWP-ASU-01 did not specify the appropriate regulatory requirement

for conducting a periodic audit of the ISFSI programs. The licensee initiated

CR 00180254 to evaluate the discrepancy.

1.3

Conclusions

Two hydrogen burn events occurred during welding of the MPC lid-to-shell welds on

canister serial numbers 168 and 169. During the welding operations for canister serial

number 168 the licensee had elected to suspend combustible gas monitoring after the

completion of the root pass weld. Although the licensee subsequently implemented

Enclosure 1

- 10 -

procedure changes to require combustible gas monitoring during the entire MPC lid-to-

shell weld process, the combustible gas monitoring configuration was ineffective in

determining the presence of combustible gases and a second hydrogen burn event

occurred during welding operations on MPC canister serial number 169. Following the

second hydrogen burn event, the licensee placed the MPC in a safe configuration and

brought in individuals with outside industry experience to determine the causes of the

hydrogen burn events and determine corrective actions to prevent recurrence. The

licensee implemented changes to introduce an inert gas (argon) beneath the MPC lid

during the lid-to-shell welding process and to relocate the explosive gas monitor sampling

point to the vicinity of the MPC vent port. The completion of the MPC lid-to-shell weld on

canister serial number 169 and the welding of the MPC lid-to-shell weld on canister serial

number 170 occurred without further incident. A Notice of Violation is being issued,

consistent with Section VI.A.1 of the NRC Enforcement Policy for failure to monitor

combustible gas concentrations during the MPC lid-to-shell weld.

The licensee procedures contained sufficient information to select and load spent fuel

assemblies into storage in compliance with CoC, Appendix B requirements. Selected fuel

assemblies were verified by the inspector to meet the CoC, Appendix B requirements.

The licensee was performing radiological surveys of canister contamination and cask

dose rates in accordance with the Technical Specification requirements. Results of

surveys performed for selected canisters and casks were well below the Technical

Specification limits.

The licensee was meeting the temperature monitoring requirements of Technical

Specification 3.1.2.1 by performing daily temperature readings of the cask outlet vents

and ambient air. All of the selected daily temperature readings reviewed were found to be

below the Technical Specification and licensee specified maximum temperature limits.

The ISFSI related condition reports sampled from the licensees corrective action system

adequately address the identified deficiencies and provide appropriate corrective actions.

The licensee was meeting the requirements of 10 CFR 72.176 for conducting periodic

audits of the ISFSI program. Deficiencies discovered during the audits were entered into

the licensee corrective action program for evaluation, as appropriate.

2

10 CFR 72.48 Evaluations (60857)

2.1

Inspection Scope

The licensees 10 CFR 72.48 program and selected 10 CFR 72.48

evaluations/screenings were reviewed to determine compliance with regulatory

requirements.

2.2

Observations and Findings

Procedure SWP-LIC-02, Licensing Basis Impact Determinations, Revision 7, provided

the overall guidance for the licensee process for meeting the requirements of

10 CFR 72.48. Section 4.3.2 instructed the preparer of the change document to perform

an applicability determination to decide which change processes apply to the proposed

Enclosure 1

- 11 -

activity, including a 10 CFR 72.48 screen or evaluation. Section 4.4.1 of Procedure SWP-

LIC-02 instructed the preparer to perform a 10 CFR 72.48 screen when directed by the

licensees applicability determination or the guidance contained in NEI 96-07, Appendix B.

Thus, Procedure SWP-LIC-02 instructed the preparer to use guidance from Procedure

SWP-LIC-02 and NEI 96-07, Appendix B when performing 10 CFR 72.48 reviews.

The licensee provided a list of the 10 CFR 72.48 screenings and single evaluation that

had been performed since the last NRC inspection conducted in March 2004. The

inspector selected 10 CFR 72.48 screen numbers 7248-04-0012, 7248-06-002 and 7248-

07-0001 along with 10 CFR 72.48 evaluation number 7248-07-002 for review. No issues

or concerns were identified with the selected 10 CFR 72.48 regulatory reviews.

During the 10 CFR 72.48 regulatory review, the inspector noted that there were no 10

CFR 72.48 screenings or evaluations that had been performed by the licensee specifically

associated with revision four or five to the Energy Northwest Independent Spent Fuel

Storage Installation 10 CFR 72.212 Evaluation.

Regulation 10 CFR 72.212(b)(2)(ii) required in part that the licensee shall evaluate any

changes to the written evaluations required by 10 CFR 72.212 using the requirements of

10 CFR 72.48(c). The 10 CFR 72.212(b) report incorporated several written evaluations

that provide documentation of how the general licensee is meeting the regulatory

requirements. The written evaluations required by 10 CFR 72.212(b)(2)(i)(A) include

showing that the conditions set forth in the CoC have been met. Holtec CoC Condition 2

required that written operating procedures for cask handling, loading, movement,

surveillance, and maintenance are consistent with the technical basis described in

Chapter 8 of the Final Safety Analysis Report (FSAR). In accordance with the

requirements of 10 CFR 72.212(b)(2)(i)(A), Energy Northwest provided a written

evaluation of how Columbia Generating Station operating procedures were meeting the

requirements of CoC Condition 2 in Section 1.1.2 of the Energy Northwest Independent

Spent Fuel Storage Installation 10 CFR 72.212 Evaluation.

As previously noted, Procedure SWP-LIC-02 directed the user to use NEI 96-07

Appendix B for guidance in determining when to perform a 10 CFR 72.48 screen.

Section B4.1.7 of NEI 96-07, Appendix B states that when a CoC holder has

screened/evaluated a cask design change under 10 CFR 72.48 and determined that prior

NRC approval is not required, a general licensee wanting to adopt the change would not

be required to do a separate screening/evaluation for the change if the site-specific

10 CFR 72.212 evaluations are not changed. However, the general licensee should

review their site-specific 10 CFR 72.212 evaluations to determine if any information would

be changed by the cask design change and, if so, perform a 10 CFR 72.48

screening/evaluation as required by 10 CFR 72.212(b)(2)(ii). The answers and/or

justification used in the 10 CFR 72.48 screening/evaluation may be taken from the CoC

holders 10 CFR 72.48 screening/evaluation if they could also apply to the general

licensee screening/evaluation.

Revision 5 of the Energy Northwest Independent Spent Fuel Storage Installation

10 CFR 72.212 Evaluation, incorporated a Holtec Supplier Manufacturing Deficiency

Report (SMDR) that reduced the number of HI-TRAC top lid bolts that were required to be

installed. This change was added to the written evaluation contained in Section 1.1.2,

Enclosure 1

- 12 -

Operating Procedures, of the Energy Northwest Independent Spent Fuel Storage

Installation 10 CFR 72.212 Evaluation. The cask vendor provided the 10 CFR 72.48

Evaluation Number 876 to Energy Northwest, which determined that prior NRC approval

was not required to implement the change. Energy Northwest utilized the Holtec SMDR

and associated 10 CFR 72.48 Evaluation as the justification for the change to Revision 5

of the Energy Northwest Independent Spent Fuel Storage Installation 10 CFR 72.212

Evaluation. A separate 10 CFR 72.48 screen or evaluation was not performed by the

licensee when incorporating the changes to the written evaluations in the Energy

Northwest Independent Spent Fuel Storage Installation 10 CFR 72.212 Evaluation. The

cask vendor 10 CFR 72.48 Evaluation Number 876 was reviewed by the inspector and

determined to adequately address the proposed change per the requirements of 10 CFR

72.48(c).

As previously stated, Regulation 10 CFR 72.212(b)(2)(ii) required in part that the licensee

shall evaluate any changes to the written evaluations required by 10 CFR 72.212 using

the requirements of 10 CFR 72.48(c). Contrary to this requirement, Energy Northwest

revised the written evaluation contained in Section 1.1.2 of the Energy Northwest

Independent Spent Fuel Storage Installation 10 CFR 72.212 Evaluation, Revision 5

without performing a 10 CFR 72.48 screen/evaluation. This is a violation of 10 CFR

72.212(b)(2)(ii). This Severity Level IV violation is being treated as a Non-Cited Violation,

consistent with Section VI.A.1 of the NRC Enforcement Policy. This violation is in the

licensees corrective action program as CR 181046.

Revision 4 of the Energy Northwest Independent Spent Fuel Storage Installation

10 CFR 72.212 Evaluation, incorporated over 40 separate changes. The licensee

incorporated administrative and editorial changes as well as changes associated with

Amendment 2 of Holtec CoC 1014. These changes were incorporated without a licensee

10 CFR 72.48 screening or evaluation associated with the 10 CFR 72.212 revision.

There were also several changes which were incorporated into written evaluations

contained in the Energy Northwest Independent Spent Fuel Storage Installation 10 CFR

72.212 Evaluation, that used a separate 10 CFR 72.48 screen/evaluation to evaluate

each proposed change. Finally, Appendix A and B were added to the Energy Northwest

Independent Spent Fuel Storage Installation 10 CFR 72.212 Evaluation, which included a

table that referenced the MPC serial numbers and the applicable Supplier Manufacturer

Deviation Reports (SMDRs) that had been issued against the MPC from the cask vendor.

After a thorough review of all the changes that had been made to Revision 4 of the

Energy Northwest Independent Spent Fuel Storage Installation 10 CFR 72.212

Evaluation, the staff determined that there were no negative findings associated with

Revision 4.

2.3

Conclusions

The licensee 10 CFR 72.48 screenings and the single 10 CFR 72.48 evaluation had been

performed in accordance with the requirements of 10 CFR 72.48(c). However, the

licensee did not perform a 10 CFR 72.48(c) review of the changes to the written

evaluations contained in Section 1.1.2 of the Energy Northwest Independent Spent Fuel

Enclosure 1

- 13 -

Storage Installation 10 CFR 72.212 Evaluation, as required by 10 CFR 72.212(b)(2)(ii).

This violation is being treated as a Non-Cited Violation, consistent with Section VI.A.1 of

the NRC Enforcement Policy.

3

Follow-up (IP 92701)

(Closed) IFI 72-35/0401-01 Review of the 10 CFR 72.212(b) Changes Needed to Support

the Hydrogen Water Chemistry Project. On April 23, 2004, the NRC issued Inspection

Report 50-397/04-07; 72-035/04-01 which included Inspection Follow-up Item (IFI) 72-

35/0201-01. The licensee had performed a 10 CFR 72.48 screening (Screen 03-010) that

had determined the storage of the hydrogen onsite and the location of the underground

hydrogen pipeline was bounded by previously analyzed accidents. The inspectors issued

IFI to review the changes made to the licensees 10 CFR 72.212 report after the hydrogen

water chemistry project had been incorporated.

The inspector reviewed the Energy Northwest Licensing Document Change Notice Form

Number LDCN 72212-03-066, and the Energy Northwest Independent Spent Fuel

Storage Installation 10 CFR 72.212 Evaluation, Revision 2, which incorporated relevant

changes associated with the hydrogen water chemistry project. The licensee had

performed a site-specific fire and explosion hazards analysis in Section 1.3.3.4, Item 5,

Fires and Explosions and < 50 Gallons of Combustible Fuel in Transporter Fuel Tank.

The analysis indicated that the existing explosion hazards analysis, which considered the

probability of a projectile impacting the HI-STORM cask during transportation or storage,

was not altered by the inclusion of the hydrogen water chemistry project. The licensee

concluded that results for the conservative calculations for all scenarios, including any

explosions associated with the hydrogen water chemistry project, continue to show that all

probabilities of a projectile impacting a HI-STORM cask are less than 10-6.

The use of a risk informed approach to determine the acceptability of the site-specific fire

and explosion hazards analysis was discussed with inspectors from the Spent Fuel

Storage and Transportation (SFST) Office. SFST determined that this was an acceptable

technique for the site-specific fire and explosion hazards analysis, as there has been no

specific regulatory restrictions placed on the methods that the general licensees could use

for this analysis and that the risk associated with an event having a frequency less than

one in 10-6 has been acknowledged by the agency as being acceptably low.

4

Exit Meeting Summary

A debrief was held with members of the licensee management at the conclusion of the

initial onsite inspection on April 17, 2008. At the conclusion of the inspection a telephonic

exit was held with members of the licensee management on May 19, 2008. The licensee

did not identify as proprietary any information provided to, or reviewed by, the inspectors.

Attachment 1

A1-1

ATTACHMENT 1

SUPPLEMENTAL IFORMATION

PARTIAL LIST OF PERSON CONTACTED

Licensee Personnel

M. Davis, Radiological Support Supervisor

R. Fuller, ISFSI Project Manager

R. Garcia, Licensing Engineer

D. Gregoire, Licensing Engineer

M. Humphries, Licensing Supervisor

C. Madden, Scientist

S. Nappi, Quality Audit

S. Rejniak, Principal Engineer

J. Suing, Reactor Maintenance Manager

Contract Personnel

C. Deady, Welder Foreman

D. Larken, ISFSI Project Manager

K. Saunders, Welder

M. Wright, Welder

INSPECTION PROCEDURES USED

60855.1

Operation of an ISFSI at Operating Plants

60857

Review of 10 CFR 72.48 Evaluations

92701

Follow-Up

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

72-35/0801-01 NOV

Failure to monitor the combustible gas concentration while performing the

MPC lid-to-shell weld

72-35/0801-02 NCV

Failure to perform 10 CFR 72.48(c) review when revising the 10 CFR

72.212(b) written evaluations

Closed

72-35/0401-01 IFI

Review of the 10 CFR 72.212(b) Changes Needed to Support the

Hydrogen Water Chemistry Project

72-35/0801-02 NCV

Failure to perform 10 CFR 72.48(c) review when revising the 10 CFR

72.212(b) written evaluations

Attachment 1

A1-2

Discussed

None

LIST OF ACRONYMS

CFR

Code of Federal Regulations

CGS

Columbia Generating Station

CoC

Certificate of Compliance

CR

Condition Report

FSAR

Final Safety Analysis Report

IFI

Inspection Follow-up Item

ISFSI

Independent Spent Fuel Storage Installation

MPC

Multi-Purpose Canister

NEI

Nuclear Energy Institute

NRC

Nuclear Regulatory Commission

PER

Problem Evaluation Request

SFST

Spent Fuel Storage and Transportation

SMDR

Supplier Manufacturing Deficiency Report

Attachment 2

A2-1

ATTACHMENT 2

LOADED HI-STORM 100S CASKS AT THE COLUMBIA GENERATING STATIONS ISFSI

LOADING

ORDER

MPC (canister)

SERIAL #

DATE

ON PAD

HEAT LOAD

(Kw)

BURNUP

MWd/MTU

MAXIMUM FUEL

ENRICHMENT %

PERSON-REM

DOSE

1

MPC-68-028

09/22/02

10.81

32,299

2.72

0.385

2

MPC-68-031

10/07/02

11.10

32,416

2.72

0.341

3

MPC-68-022

10/28/02

11.30

32,541

2.72

0.315

4

MPC-68-039

11/18/02

11.42

33,045

2.72

0.298

5

MPC-68-033

12/09/02

11.20

32,804

2.72

0.245

6

MPC-68-091

02/25/04

12.00

32,318

2.72

0.390

7

MPC-68-092

03/03/04

17.10

38,607

2.92

0.298

8

MPC-68-093

03/11/04

17.10

38,738

2.92

0.320

9

MPC-68-094

03/18/04

17.00

38,732

2.92

0.304

10

MPC-68-095

03/24/04

17.00

38,772

2.92

0.276

11

MPC-68-096

03/31/04

17.10

38,729

2.92

0.253

12

MPC-68-097

04/06/04

17.20

39,121

2.92

0.251

13

MPC-68-098

04/14/04

17.10

39,002

2.92

0.237

14

MPC-68-099

04/20/04

17.00

39,008

2.92

0.208

15

MPC-68-100

04/25/04

16.80

38,982

2.92

0.199

16

MPC-68-162

02/22/08

11.91

39,172

3.22

0.260

17

MPC-68-163

02/29/08

21.00

43,302

3.56

0.458

18

MPC-68-164

03/07/08

21.02

43,181

3.56

0.426

19

MPC-68-165

03/14/08

21.02

43,010

3.56

0.343

20

MPC-68-166

03/21/08

21.00

43,330

3.56

0.379

21

MPC-68-167

04/04/08

21.03

42,827

3.56

0.587

22

MPC-68-168

04/11/08

21.01

43,020

3.56

0.503

23

MPC-68-169

04/29/08

20.88

42,269

3.87

0.362

Notes:

1) Heat Load (Kw) is the sum of the heat load values for all spent fuel assemblies in the cask

2) Burnup is the value for the spent fuel assembly with the highest individual discharge burnup

3) Fuel Enrichment is the spent fuel assembly with the highest individual enrichment percent of U-235