ML092100311

Presentation Slides, SFST June 2009 Monthly Seminar - Operational Experience.

ML092100311
Person / Time
Site:	Grand Gulf
Issue date:	07/29/2009
From:	Ellis D Entergy Operations
To:	NRC/NMSS/SFST
Vechioli, L NMSS/SFST 492-3276
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ML092100117	List: ML092100311
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Download: ML092100311 (16)

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OPERATIONAL EXPERIENCE Implementing a New CoC Amendment for Dr Dry Storage Dave Ellis, Entergy Operations, Inc Grand Gulf Nuclear Station

Why Do This?

z To increase the flexibility of the ISFSI due to continuous evolution in the industry Because:

z Fuel Types can change z Heat Load can change z Fuel Weights typically will go up z Other design considerations

Schedule - CoC z You must maintain a 5 to 8 year planning horizon in your loading strategy z New CoC Amendments can take 2 - 4 years y z Certificate Holder must be involved from time fuel is purchased p

z Nuclear Engineering must determine before fuel purchase if there will be impairments to licensing the fuel for dry storage.

Schedule - Implementation z T 48 Months - Notification to Certificate Holder of need for Amendment z T-24 Months - Order storage system z T-16 Months - Assess changes to program based b d on CCoCCAAmendment d t selected

Schedule - Implementation z T-9 Months - Assessment Complete z T-9 Months - Decision on what changes will be made based on assessment results z T-7 Months - Start changes to programs z T-5 Months - Train on changes and change procedures

Stakeholder Impact Management Site Staff Management, Staff, and Regulator z Budget for changes 3 - 5 years in advance d

z Management briefings on the WHY z Proactive regulator (site) briefings on details z Site staff communication EARLY

Stakeholder Impact - Engineering z Comparative review of drawings drawings, calcs calcs, assumptions from original licensing of the facility against new FSAR and CoC z Heavy Loads z Seismic spectra z Industry Code changes z Heat load effects on SSC z Component Data Base updates

Stakeholder Impact - Licensing z 72.212 Evaluation Report will be affected z Facility y FSAR can be affected so dont g get tunnel vision on the 72.48 evaluation, y

everythingg also needs to p pass 50.59 muster

Stakeholder Impact - Training z Workers that perform ITS functions must be trained z Continuing training for the existing cask systems z Training on the new cask system to be deployed z Specific attention needs to be paid to Operations understanding of multiple/different C C Tech CoC T h Specs, S andd how h tto determine d t i which hi h cask is governed by what specific CoC Amendment.

Amendment

Stakeholder Impact - Operations z Operations p p performs the daily y cask surveillances z They also determine operability of the cask system and initiate associated LCOs z Make sure that they understand the difference between the CoCs and Tech Specs of the different cask systems z Make sure that OPs procedures address the different d e e t su surveillance e a ce requirements equ e e ts a andd LCOs.

COs Itt is GOOD to provide the explanation IN THE PROCEDURE.

Stakeholder Impact - Procedures z Procedures need to address all versions of the cask system z Independent verification on steps that implement CoC Tech Specs z Independent verification on steps that are different for different casks systems z You should expect that at least 50% of the procedures will have to be changed

Documentation z Engineering reviews of new FSAR and CoC will find things z Some things require changes and some dont z The Th iimportant t t thi thing iis tto d documentt what h t you find and provide justification for changing h i or nott changing h i

Documentation z You may also find errors from previous evaluations or reviews.

z These may affect both existing in in--service systems and the proposed new system.

z These Th should h ld bbe addressed dd d via i th the Corrective Action process and in the d

documentation t ti ffor the th new CoC.

C C

Dry Run Demonstrations or Not?

z The CoCs will specify p y the Dry y Run requirements q and they must be done.

done.

z However, it is acceptable to credit dry runs already performed at your site on substantially identical systems and procedures.

z Make sure that your 72.212 evaluation clearly states what was done to satisfy the requirements of the new CoC.

z Sometimes, key processes demonstrated for previous d runs d dry do nott supportt new procedures d iin new FSAR or CoC. Partial dry runs of discrete steps may need to be performed and documented

Things you may find along the way z Errors in the Cask System FSAR - work with the CoC HOLDER z Procedures described in the CoC that are nott described d ib d in i the th FSAR

OPERATIONAL EXPERIENCE Implementing a New CoC Amendment for Dr Dry Storage Dave Ellis, Entergy Operations, Inc Grand Gulf Nuclear Station