ML092100311
| 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 | |
| Shared Package | |
| ML092100117 | List: |
| References | |
| Download: ML092100311 (16) | |
Text
OPERATIONAL OPERATIONAL OPERATIONAL OPERATIONAL EXPERIENCE EXPERIENCE EXPERIENCE EXPERIENCE Implementing a New CoC Implementing a New CoC Amendment for Dr Storage Amendment for Dr Storage Amendment for Dry Storage Amendment for Dry Storage Dave Ellis, Entergy Operations, Inc Grand Gulf Nuclear Station Grand Gulf Nuclear Station
Why Do This?
Why Do This?
Why Do This?
Why Do This?
z To increase the flexibility of the ISFSI due to To increase the flexibility of the ISFSI due to z To increase the flexibility of the ISFSI due to To increase the flexibility of the ISFSI due to continuous evolution in the industry continuous evolution in the industry Because:
Because:
z Fuel Types can change Fuel Types can change z Fuel Types can change Fuel Types can change z Heat Load can change Heat Load can change z Fuel Weights typically will go up Fuel Weights typically will go up z Fuel Weights typically will go up Fuel Weights typically will go up z Other design considerations Other design considerations
Schedule Schedule - CoC CoC Schedule Schedule CoC CoC z You must maintain a 5 to 8 year planning You must maintain a 5 to 8 year planning z You must maintain a 5 to 8 year planning You must maintain a 5 to 8 year planning horizon in your loading strategy horizon in your loading strategy z New CoC Amendments can take 2 New CoC Amendments can take 2 - 4 years 4 years y
z Certificate Holder must be involved from time Certificate Holder must be involved from time fuel is purchased fuel is purchased p
z Nuclear Engineering must determine Nuclear Engineering must determine before fuel before fuel purchase purchase if there will be impairments to licensing if there will be impairments to licensing the fuel for dry storage.
the fuel for dry storage.
Schedule Schedule - Implementation Implementation Schedule Schedule Implementation Implementation z T-60 60 - 48 Months 48 Months - Notification to Notification to z T 60 60 48 Months 48 Months Notification to Notification to Certificate Holder of need for Amendment Certificate Holder of need for Amendment z T 24 Months 24 Months Order storage system Order storage system z T-24 Months 24 Months - Order storage system Order storage system z T--16 Months 16 Months - Assess changes to Assess changes to b
d C C A d
t b
d C C A d
t program based on CoC Amendment program based on CoC Amendment selected selected
Schedule Schedule - Implementation Implementation Schedule Schedule Implementation Implementation z T--9 Months 9 Months - Assessment Complete Assessment Complete z T 9 Months 9 Months Decision on what changes Decision on what changes z T-9 Months 9 Months - Decision on what changes Decision on what changes will be made based on assessment results will be made based on assessment results z T--7 Months 7 Months - Start changes to programs Start changes to programs z T--5 Months 5 Months - Train on changes and Train on changes and change procedures change procedures
Stakeholder Impact Stakeholder Impact Management Site Staff and Management Site Staff and Management, Site Staff, and Management, Site Staff, and Regulator Regulator z Budget for changes 3 Budget for changes 3 -- 5 years in 5 years in d
advance advance z Management briefings on the WHY Management briefings on the WHY z Proactive regulator (site) briefings on Proactive regulator (site) briefings on details details z Site staff communication EARLY Site staff communication EARLY
Stakeholder Impact Stakeholder Impact - Engineering Engineering Stakeholder Impact Stakeholder Impact Engineering Engineering z Comparative review of drawings calcs Comparative review of drawings calcs z Comparative review of drawings, calcs, Comparative review of drawings, calcs, assumptions from original licensing of the assumptions from original licensing of the facility against new FSAR and CoC facility against new FSAR and CoC facility against new FSAR and CoC facility against new FSAR and CoC z Heavy Loads Heavy Loads z Seismic spectra Seismic spectra z Seismic spectra Seismic spectra z Industry Code changes Industry Code changes Heat load effects on SSC Heat load effects on SSC z Heat load effects on SSC Heat load effects on SSC z Component Data Base updates Component Data Base updates
Stakeholder Impact Stakeholder Impact - Licensing Licensing Stakeholder Impact Stakeholder Impact Licensing Licensing z 72.212 Evaluation Report will be affected 72.212 Evaluation Report will be affected z Facility FSAR can be affected so dont get Facility FSAR can be affected so dont get y
g y
g tunnel vision on the 72.48 evaluation, tunnel vision on the 72.48 evaluation, everything also needs to pass 50.59 everything also needs to pass 50.59 y
g p
y g
p muster muster
Stakeholder Impact Stakeholder Impact - Training Training Stakeholder Impact Stakeholder Impact Training Training z Workers that perform ITS functions must be Workers that perform ITS functions must be z Workers that perform ITS functions must be Workers that perform ITS functions must be trained trained z Continuing training for the existing cask systems Continuing training for the existing cask systems z Training on the new cask system to be deployed Training on the new cask system to be deployed z Specific attention needs to be paid to Specific attention needs to be paid to Operations understanding of multiple/different Operations understanding of multiple/different C C T h S d h t
d t i
hi h C C T h S d h t
d t i
hi h CoC Tech Specs, and how to determine which CoC Tech Specs, and how to determine which cask is governed by what specific CoC cask is governed by what specific CoC Amendment Amendment Amendment.
Amendment.
Stakeholder Impact Stakeholder Impact - Operations Operations Stakeholder Impact Stakeholder Impact Operations Operations z Operations performs the daily cask surveillances Operations performs the daily cask surveillances p
p y
p p
y z They also determine operability of the cask They also determine operability of the cask system and initiate associated LCOs system and initiate associated LCOs z Make sure that they understand the difference Make sure that they understand the difference between the CoCs and Tech Specs of the between the CoCs and Tech Specs of the different cask systems different cask systems different cask systems different cask systems z Make sure that OPs procedures address the Make sure that OPs procedures address the different surveillance requirements and LCOs. It different surveillance requirements and LCOs. It d e e t su e a ce equ e e ts a d COs t
d e e t su e a ce equ e e ts a d COs t
is GOOD to provide the explanation IN THE is GOOD to provide the explanation IN THE PROCEDURE.
PROCEDURE.
Stakeholder Impact Stakeholder Impact - Procedures Procedures Stakeholder Impact Stakeholder Impact Procedures Procedures z Procedures need to address all versions of Procedures need to address all versions of z Procedures need to address all versions of Procedures need to address all versions of the cask system the cask system z Independent verification on steps that Independent verification on steps that z Independent verification on steps that Independent verification on steps that implement CoC Tech Specs implement CoC Tech Specs z Independent verification on steps that are Independent verification on steps that are z Independent verification on steps that are Independent verification on steps that are different for different casks systems different for different casks systems z You should expect that at least 50% of the You should expect that at least 50% of the z You should expect that at least 50% of the You should expect that at least 50% of the procedures will have to be changed procedures will have to be changed
Documentation Documentation Documentation Documentation z Engineering reviews of new FSAR and Engineering reviews of new FSAR and z Engineering reviews of new FSAR and Engineering reviews of new FSAR and CoC will find things CoC will find things z Some things require changes and some Some things require changes and some z Some things require changes and some Some things require changes and some dont dont Th i
t t thi i t d
t h t Th i
t t thi i t d
t h t z The important thing is to document what The important thing is to document what you find and provide justification for you find and provide justification for h
i t h i
h i
t h i
changing or not changing changing or not changing
Documentation Documentation Documentation Documentation z You may also find errors from previous You may also find errors from previous z You may also find errors from previous You may also find errors from previous evaluations or reviews.
evaluations or reviews.
z These may affect both existing in These may affect both existing in service service z These may affect both existing in These may affect both existing in-service service systems and the proposed new system.
systems and the proposed new system.
Th h
ld b dd d i th Th h
ld b dd d i th z These should be addressed via the These should be addressed via the Corrective Action process and in the Corrective Action process and in the d
t ti f
th C C d
t ti f
th C C documentation for the new CoC.
documentation for the new CoC.
Dry Run Demonstrations or Not?
Dry Run Demonstrations or Not?
Dry Run Demonstrations or Not?
Dry Run Demonstrations or Not?
z The CoCs will specify the Dry Run requirements The CoCs will specify the Dry Run requirements and and p
y y
q p
y y
q they must be done they must be done.
z However, it is acceptable to However, it is acceptable to credit credit dry runs already dry runs already performed at your site on substantially identical systems performed at your site on substantially identical systems performed at your site on substantially identical systems performed at your site on substantially identical systems and procedures.
and procedures.
z Make sure that your 72.212 evaluation clearly states Make sure that your 72.212 evaluation clearly states what was done to satisfy the requirements of the new what was done to satisfy the requirements of the new what was done to satisfy the requirements of the new what was done to satisfy the requirements of the new CoC.
CoC.
z Sometimes, key processes demonstrated for previous Sometimes, key processes demonstrated for previous d
d t
t d
i FSAR d
d t
t d
i FSAR dry runs do not support new procedures in new FSAR or dry runs do not support new procedures in new FSAR or CoC. Partial dry runs of discrete steps may need to be CoC. Partial dry runs of discrete steps may need to be performed and documented performed and documented
Things you may find along the way Things you may find along the way Things you may find along the way Things you may find along the way z Errors in the Cask System FSAR Errors in the Cask System FSAR - work work z Errors in the Cask System FSAR Errors in the Cask System FSAR work work with the CoC with the CoC HOLDER HOLDER z Procedures described in the CoC that are Procedures described in the CoC that are t d ib d i th FSAR t d ib d i th FSAR not described in the FSAR not described in the FSAR
OPERATIONAL OPERATIONAL OPERATIONAL OPERATIONAL EXPERIENCE EXPERIENCE EXPERIENCE EXPERIENCE Implementing a New CoC Implementing a New CoC Amendment for Dr Storage Amendment for Dr Storage Amendment for Dry Storage Amendment for Dry Storage Dave Ellis, Entergy Operations, Inc Grand Gulf Nuclear Station Grand Gulf Nuclear Station