NL-10-0015, Isfsis, Follow-up Actions - NRC Enforcement Discretion Letter EA-09-190, Holtec Elimination of MPC Shop Helium Leak Rate Test

Isfsis, Follow-up Actions - NRC Enforcement Discretion Letter EA-09-190, Holtec Elimination of MPC Shop Helium Leak Rate Test

ML100250991
Person / Time
Site:	Hatch, Farley, 07200042, 07200036
Issue date:	01/25/2010
From:	Ajluni M Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
EA-09-190, NL-10-0015
Download: ML100250991 (8)

Text

SOllthern Nuclear Operating Company, InL January 25,2010 SOUTHERN A.

COMPANY Docket Nos.: 50-321 50-348 NL-10-0015 50-366 50-364 72-36 72-42 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Joseph M. Farley Nuclear Plant Follow-up Actions - NRC Enforcement Discretion Letter EA-09-190, Holtec Elimination of MPC Shop Helium Leak Rate Test Ladies and Gentlemen:

The Nuclear Regulatory Commission (NRC) notified Holtec International (Holtec) regarding a violation of NRC requirements by letter dated August 6,2006.

Specifically, Holtec eliminated shop helium leak testing of the multi-purpose canister (MPC) during fabrication without prior NRC approval. By letter dated September 2, 2009, Holtec provided a response to the violation which included analysis that supports continued use of loaded MPCs that were not tested during fa brication.

Southern Nuclear Operating Company (SNC) is the licensed operator of the Edwin I. Hatch Nuclear Plant (Hatch) and the Joseph M. Farley Nuclear Plant (Farley) and is the general licensee for the independent spent fuel storage installations (ISFSls) at these facilities. SNC currently has loaded MPCs in storage in both the Hatch and Farley ISFSls that were not helium leak tested during fabrication.

A teleconference was held on December 1, 2009, with NRC, Holtec, and affected licensees participating in the call. In this call, the NRC requested that general licensees with MPCs that were not helium leak tested during fabrication provide information related to their site-specific determinations that the MPCs could remain in service. Accordingly, the requested information is provided in and 2 for Hatch and Farley, respectively.

U. S. Nuclear Regulatory Commission NL-10-0015 Page 2 This letter contains no NRC commitments. If you have any questions, please advise.

Sincerely,

~~~

Mark J. Ajluni Manager - Nuclear Licensing MJAITWSllac

Enclosure:

cc: Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. J. R. Johnson, Vice President - Farley Mr. D. R. Madison, Vice President - Hatch Ms. P. M. Marino, Vice President - Engineering RType: CFA04.054; CHA02.004 U. S. Nuclear Regulatory Commission Mr. LA. Reyes, Regional Administrator Mr. R. E. Martin, NRR Project Manager - Farley Ms. D. N. Wright, NRR Project Manager - Hatch Mr. E. L Crowe, Senior Resident Inspector - Farley Mr. J. A. Hickey, Senior Resident Inspector - Hatch

Edwin I. Hatch Nuclear Plant Joseph M. Farley Nuclear Plant Follow-up Actions - NRC Enforcement Discretion Letter EA-09-190, Holtec Elimination of MPC Shop Helium Leak Rate Test Enclosure 1 NRC Requested Information - Hatch

Enclosure 1 NRC Requested Information - Hatch A teleconference was held by the NRC with Holtec and general licensees with loaded MPCs that were not subjected to helium leak testing during fabrication for the purpose of discussing continued use of the affected MPCs. The following list, taken from the NRC Conversation Record (ML09351000082), identifies the information requested by the NRC. The requested information for Hatch is provided immediately following the NRC requested information below.

1. NRC Request:

Information that the thermal heat load for the spent fuel and internal helium conditions that had been loaded into the MPCs was bounded by the thermal and over pressure helium analyses provided by Holtec in their corrective action response to the NRC Enforcement Discretion letter dated August 6, 2009; for MPCs loaded above 21 kilowatts (kW) the NRC requested that the site provide information regarding the length of time that would elapse before the spent fuel heat load would decay below 21 kW.

SNC Response:

Hatch currently has eight MPCs loaded with spent fuel in the ISFSI that were not helium leak tested during fabrication. Four of these casks were loaded during the summer 2007 campaign in accordance with the requirements of CoC 1014, Amendment 2, and four were loaded during the summer 2008 campaign to CoC Amendment 3. The maximum heat load for these MPCs is 19.1 kW. Accordingly, these casks are bounded by the thermal and over pressure helium analyses provided by Holtec letter to the NRC dated September 2, 2009.

2. NRC Request:

Information that the site radiological monitoring programs had not detected any adverse effluent conditions associated with the use of the MPCs, and that all measured site radiological parameters were within the limits provided in 10 CFR 72.104.

SNC Response:

SNC has reviewed the results of the Annual Radiological Environmental Operating Reports since the beginning of ISFSI storage operations in 2000. The results of this review determined that there is no discernable increase in dose to the public as the result of storage of casks that were not helium leak tested. Results contained in the Annual Radiological Environmental Operating Report for this period were within the limits specified in 10 CFR 72.104. Based on: (1) absence of identified leakage from MPCs that have been previously tested; and (2) use of the same stringent fabrication requirements; leakage 'from these casks is not E1-1

Enclosure 1 NRC Requested Information - Hatch considered credible. Accordingly, these casks are bounded by the existing SNC analysis for compliance with 10 CFR 72.104.

3. NRC Request:

Information that the sites dispositioned the deficiency through their non conforming and corrective action process and determined that continued use of the MPCs was found to be acceptable.

SNC Response:

Condition Report 2009107859 was entered for Holtec failure to perform the required helium leak test during fabrication. A prompt determination of operability was prepared in conjunction with this CR and a determination made that the affected MPCs would perform their intended safety function. This determination was based on the analysis contained in Holtec Report HI-2094407, summarized in the Holtec response to the violation dated September 2, 2009.

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Edwin I. Hatch Nuclear Plant Joseph M. Farley Nuclear Plant Follow-up Actions - NRC Enforcement Discretion Letter EA-09-190, Holtec Elimination of MPC Shop Helium Leak Rate Test Enclosure 2 NRC Requested Information - Farley

Enclosure 2 NRC Requested Information - Farley A teleconference was held by the NRC with Holtec and general licensees with loaded MPCs that were not subjected to helium leak testing during fabrication for the purpose of discussing continued use of the affected MPCs. The following list, taken from the NRC Conversation Record (ML09351000082), identifies the information requested by the NRC. The requested information for Farley is provided immediately following the NRC requested information below.

1. NRC Request:

Information that the thermal heat load for the spent fuel and internal helium conditions that had been loaded into the MPCs was bounded by the thermal and over pressure helium analyses provided by Holtec in their corrective action response to the NRC Enforcement Discretion letter dated August 6, 2009; for MPCs loaded above 21 kilowatts (kW) the NRC requested that the site provide information regarding the length of time that would elapse before the spent fuel heat load would decay below 21 kW.

SNC Response:

Farley currently has four MPCs loaded with spent fuel in the ISFSI that were not helium leak tested during fabrication that were loaded during the summer 2007 campaign in accordance with the requirements of CoC 1014, Amendment 3. The maximum heat load for these MPCs is 26.5 kW. Accordingly, these casks are bounded by the thermal and over pressure helium analyses provided by Holtec letter to the NRC dated September 2, 2009. The heat load for these casks is projected to be less than 21 kW by December 31,2014.

2. NRC Request:

Information that the site radiological monitoring programs had not detected any adverse effluent conditions associated with the use of the MPCs, and that all measured site radiological parameters were within the limits provided in 10 CFR 72.104.

SNC Response:

SNC has reviewed the results of the Annual Radiological Environmental Operating Reports since the beginning of ISFSI storage operations in 2005. The results of this review determined that there is no discernable increase in dose to the public as the result of storage of casks that were not helium leak tested. Results contained in the Annual Radiological Environmental Operating Report for this period were within the limits specified in 10 CFR 72.104. Based on: (1) absence of identified leakage from MPCs that have been previously tested; and (2) use of the same stringent fabrication requirements; leakage from these casks is not E2-1

Enclosure 2 NRC Requested Information Farley considered credible. Accordingly, these casks are bounded by the existing SNC analysis for compliance with 10 CFR 72.104.

3. NRC Request:

Information that the sites dispositioned the deficiency through their non conforming and corrective action process and determined that continued use of the MPCs was found to be acceptable.

SNC Response:

Condition Report 2009109653 was entered for Holtec failure to perform the required helium leak test during fabrication. A prompt determination of operability was prepared in conjunction with this CR and a determination made that the affected MPCs would perform their intended safety function. This determination was based on the analysis contained in Holtec Report HI-2094407, summarized in the Holtec response to the violation dated September 2, 2009.

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