ML111890441

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IR 05000277-10-010 on 11/01/2010 - 05/27/2011, Peach Bottom, ISFSI Inspection
ML111890441
Person / Time
Site: Peach Bottom Constellation icon.png
Issue date: 07/08/2011
From: Joustra J
Decommissioning Branch I
To: Pacilio M
Exelon Nuclear, Exelon Generation Co
References
IR-10-010
Download: ML111890441 (12)


See also: IR 05000277/2010010

Text

UNITED STATES

NUCLEAR REGULATORY COM MISSION

REGION I

475 ALLENDALE ROAD

KING OF PRUSSIA, PENNSYLVANIA 19406-1415

July 8,2011

Docket No. 05000277 License No. DPR-44

MichaelJ. Pacilio

Senior Vice President, Exelon Generation Company, LLC

President and Chief Nuclear Officer, Exelon Nuclear

4300 Winfield Road

Warrenville. lL 60555

SUBJECT: PEACH BOTTOM ATOMIC POWER STATION - NRC ISFSI INSPECTION

REPORT 05000277 1201 00 1 0

Dear Mr. Pacilio:

On November 1 , 2010 through May 27 ,2011 , Mark Roberts, John Nicholson, and Stephen

Hammann of this office conducted a safety inspection at the Peach Bottom Atomic Power

Station of activities authorized by the above listed NRC license. The inspection was limited to a

review of routine and non-routine (helium leak of cask #1) activities associated with dry fuel

storage at the Peach Bottom Atomic Power Station and its Independent Spent Fuel Storage

Installation (lSFSI). The findings of the inspection were discussed with Garey Strathes, and

other members of your staff of your organization, at the conclusion of the inspection. The

enclosed report presents the results of this inspection.

The inspection examined activities conducted under your license as they relate to compliance

with the Commission's rules and regulations and with the conditions of your license. The

inspectors reviewed selected procedures and records, observed activities, and interviewed

personnel.

Based on the results of this no findings of significance were identified.

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

enclosure, and your response (if any) will be available electronically for public inspection in the

NRC Public Document Room or from the Publicly Available Records component of the NRC's

document system (ADAMS). ADAMS is accessible from the NRC Web Site at

http ://vr,rww. nrc. qov/readi no-rm/adams. html (the Pu blic Electric Reading Room).

M. Pacillo

Thank you for your cooperation during this inspection.

Decommissioning Branch

Division of Nuclear Materials Safety

Enclosure:

lnspection Report No. 05000277 l2O1OO1O

cc: dencl: Distribution via List Serv

M. Pacillo

Thank you for your cooperation during this inspection.

Sincerely,

/RA/ Kathy Modes for:

Judith A. Joustra, Chief

Decommissioning Branch

Division of Nuclear Materials Safety

Enclosure:

f nspection Report No. 05000277 12010010

cc: Mencl: Distribution via List Serv

Distribution w/encl: (via E-mail)

W. Dean, RA (RIORAMAIL Resource) S. lbarrola. DRP

D. Lew, DRA (RIORAMAlL Resource) F. Bower, DRP, SRI

D. Roberts, DRP (RIDRPMAlL Resource) A. Ziedonis, DRP, Rl

J. Clifford, DRP (RIDRPMAlL Resource) S. Schmitt, DRP, OA

C. Miller, DRS (RlDRSMailResource) S. Bush-Goddard, Rl OEDO

RidsNrrPMPeachBottom Resource

P. Wilson, DRS (RlDRSMail Resource)

RidsNrDorlLpl 1 -2 Resource

P. Krohn, DRP

ROPreoorts Resource

A. Rosebrook, DRP

E. Torres, DRP

E. Benner, NMSS

J. Joustra, DNMS

R. Lorson, DNMS

D. Collins, DNMS

M. Roberts, DNMS

S. Hammann, DNMS

J. Nicholson, DNMS

D. Screnci, PAO

N. Sheehan. PAO

DOCUMENT NAME: G :\WordDocs\Current\lnsp Letter\LDPR-44.201 00 1 0'doc

SUNSI Review Complete: MRoberts ML111890441

After declaring this document 'An Official Agency Record' it will be released to the Public.

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OFFICE DNMS/RI I N DNMS/RI DNMS/RI DNMS/RI

NAME MRoberts/mcr JNicholsonimcr for: SHammann/sth JJoustra/kdm for

0710812011 07t08t2011 07t08t2011 0710812011

DATE

OFFICIAL RECORD COPY

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

INSPECTION REPORT

lnspection No. 45400277t2010010

Docket No. 05000277

License No. DPR-44

Licensee: Exelon Nuclear

Location: Peach Bottom Atomic Power Station

1848 Lay Road

Delta, PA.17314

Inspection Dates: November 1,2010 - May 27,2011

lnspectors: Mark Roberts, Senior Health Physicist

Decommissioning Branch

Division of Nuclear Materials Safety

Stephen Hammann, Senior Health Physicist

Decommissioning Branch

Division of Nuclear Materials Safety

John Nicholson, Health Physicist

Decommissioning Branch

Division of Nuclear Materials Safety

Fred Bower, Peach Bottom Senior Resident Inspector

Branch 4

Division of Reactor Projects

Adam Ziedonis, Peach Bottom Resident lnspector

Branch 4

Division of Reactor Projects

Approved By: Judith A. Joustra, Chief

Decommissioning Branch

Division of Nuclear Materials Safety

Document Name: G:\WordDocs\Current\lnsp Report\RDPR-44.201 001 0.doc

EXECUTIVE SUMMARY

Exelon Nuclear

Peach Bottom Atomic Power Station

NRC lnspection Report No. 0500027712010010

The inspection was a review of spent fuel storage activities at the Peach Bottom Atomic Power

Station and the Independent Spent Fuel Storage lnstallation (lSFSl) at the site. The inspection

included a review of activities during a routine spent fuel storage campaign and the

troubleshooting, unloading, root cause evaluation, and corrective action development of a

loaded spent fuel storage cask that had developed a helium leak in the main lid seal. The report

covers announced safety inspection visits conducted by three regional inspectors with support

from two NRC resident inspectors. The inspection included an evaluation of the licensee's

programs for radiation protection, maintenance, and operations as they related to routine

preparation, loading, and transport of a spent fuel cask and the non-routine activities associated

with troubleshooting the helium leak, opening and unloading a loaded cask, conducting a causal

analysis for the leaking cask, and developing and implementing corrective actions.

The licensee safely implemented its maintenance, radiation protection, and operations programs

to support routine and non-routine activities associated with dry fuel storage.

Based on the results of this inspection, no findings were identified.

lnspection Report No. 05000277 12010010

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REPORT DETAILS

1.0 Helium Leak ldentification on ISFSI Gask #1

a. lnspection Scope

The inspectors reviewed the activities related to the response to a low pressure alarm

condition on spent fuel storage cask TN-68-01. The inspectors interviewed personnel

and reviewed the licensee's relevant documents.

b. Observations and Findinqs

Exelon Nuclear utilizes the Transnuclear, Inc. (Transnuclear) TN-68 cask storage system

at the Peach Bottom site for storage of spent fuel assemblies at its lSFSl. TheTN-68

casks are vertical stainless steel casks with bolted lids. A metal (aluminum-clad) O-ring

seal with an inner and an outer sealing surface is fitted into a groove in the bottom of the

cask lid. After loading a cask in the fuel pool with spent fuel assemblies, the cask lid is

bolted on and residual moisture is removed from the cask. When the lid bolts are

torqued into the lid, the two sealing surfaces of the metal O-ring are compressed against

the top of the cask to form two seals. Access to the cask once the lid is in place is

through a pair of vent and drain ports. The cask is back-filled with helium and the drain

and vent ports are bolted on. The vent and drain port covers also have metal O-ring

seals with inner and outer sealing surfaces. The helium backfill provides an inert storage

environment. A helium overpressure tank, positioned on a small port on the cask lid,

supplies helium overpressure to the space between the cask seals. The combined

helium leak rate for all closure seals and the overpressure system is continuously

monitored for indications of helium leakage and compliance with the Certificate of

Compliance (COC) technical specifications. A bolted on carbon steel protective cover,

with an elastomer O-ring seal, provides environmental protection for the cask lid and

helium pressurization system. Currently approximately 50 casks are stored at the Peach

Bottom lSFSl.

On October 11,2010, a cask seal overpressure monitoring system low pressure alarm

was received for Cask TN-68-01. This cask was initially loaded with spent fuel

assemblies on June 12,2000, and was in storage at the lSFSl. Preliminary helium leak-

testing was conducted at the lSFSl. In order to perform further troubleshooting of the low

pressure alarm, the overpressure monitoring system was re-pressurized and the cask

was moved to the Unit 2 Containment Building. Testing conducted on October 27,2010,

identified that a helium leak existed in the cask main lid sealing area at a leak rate

greater than allowed by the ISFSI cask COC technical specifications.

No findings of significance were identified.

c. Conclusions

The licensee identified and responded to a cask seal overpressure monitoring system

low pressure alarm for Cask TN-68-01. The cask was safely moved to the Unit 2

Containment Building where testing confirmed a helium leak in the cask main lid sealing

area at a leak rate greater than allowed by the ISFSI cask COC technical specifications.

1 Inspection Report No. 0500027712010010

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2.0 Helium Leak Troubleshooting on ISFSI Gask #1

a. Inspection Scope

The inspectors reviewed the activities related to troubleshooting the low pressure alarm

condition on cask TN-68-01. The inspectors observed troubleshooting activities

performed on the cask, interviewed personnel, and reviewed the licensee's relevant

documents.

b. Observations and Findinqs

The licensee, in consultation with Transnuclear, re-torqued each of the 48 cask lid bolts

progressively to a level of 900 foot-pounds. The bolt torque sequence was provided by

Transnuclear. Torquing was repeated until there was no visual movement of any bolt

head. The licensee then performed a sequence of helium leak tests and identified that

the outer sealing surface of the main cask lid seal was leaking. The cask inner seal and

the seals on the vent and drain ports were confirmed to be functional. Although the

licensee was able to reduce the helium leak-rate to levels below the requirements of the

COC technical specifications, they decided that they did not want to return the cask to

long-term storage at the lSFSl. Plans were then developed to breach the cask and

unload the spent fuel assemblies back into the spent fuel pool in order to perform

additional inspections on the cask lid and seals.

No findings of significance were identified.

c. Conclusions

The licensee conducted helium leak test troubleshooting of a loaded spent fuel storage

cask and confirmed that the outer sealing surface of the main cask lid seal was leaking.

Plans were developed to breach the cask and unload the spent fuel assemblies back into

the spent fuel pool in order to perform additional inspections on the cask seals.

3.0 Spent Fuel Unloading Activities for ISFSI Cask #1

a. lnspection Scope

The inspectors reviewed the licensee's activities associated with opening the cask,

returning the cask to the spent fuel pool, and unloading the spent fuel back into the spent

fuel poolfuel storage racks. The inspectors interviewed licensee personnel, reviewed

planning documents, and directly observed activities associated with opening, moving,

and unloading the spent fuel cask.

b. Observations and Findinos

The licensee had confirmed through testing that each of the fuel assemblies that were

loaded into the cask were not leaking, when the cask was initially loaded. However,

because the condition of the fuel assemblies in the cask were unknown after ten years of

storage, licensee staff took conservative measures in coordinating maintenance and

radiation protection activities to safely breach the cask. In addition to their own practical

2 Inspection Report No. 0500027712010010

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experience gained from loading spent fuel casks, the licensee used operating experience

gained from another operating nuclear power plant licensee that breached loaded fuel

casks with a similar helium leak problem. Major concerns that were considered if the fuel

integrity had not been maintained were the potential for elevated radiation levels at the

drain and vent port covers, high activity discrete radioactive particles, and release of

fission product gasses. Pre-job briefings by maintenance and radiation protection

personnelwere thorough and appropriately emphasized the areas of major concern.

Radiation protection surveys did not identify significantly elevated radiation levels or

discrete radioactive particles. Radiological surveys and sampling and analysis of the

atmosphere in the cask did not identify any release of fission product gasses once the

cask was breached. The cask was then placed in the Unit 2 fuel pool for removal of the

lid and unloading the fuel assemblies. The cask lid and cask were returned to Unit 2 fuel

floor for inspection and evaluation.

No findings of significance were identified.

c. Conclusions

The licensee safely implemented its plan for breaching the spent fuel cask, placing the

cask in the spent fuel pool, removing the cask lid, unloading spent fuel from the cask,

and returning the cask lid and cask to the fuel floor for inspection. No unusual or

unexpected conditions were identified.

4.0 Evaluation and Gorrective Action Activities

a. lnspection Scope

The inspectors reviewed the licensee's activities associated with the cask seal

evaluation, extent of condition implications, and corrective actions that had been

implemented and proposed. The inspection consisted of field observations, review of

licensee documentation, and interviews with responsible personnel.

b. Observations and Findinqs

Licensee and cask vendor personnel inspected the cask, cask lid, cask lid seals, vent

and drain cover seals, protective cover, and the sealing surfaces on the protective cover.

The inspections of the protective cover were performed during the initial cask

disassembly on the fuel floor. The inspections of the cask, lid, and seals were conducted

after the unloaded cask was returned to the fuel floor. The initial evaluation revealed

corrosion of the main lid outer seal, lower-than-expected torque on some of the main lid

bolts, and corrosion on the threads of the lid bolts. The inner seal remained intact, and

therefore the cask's primary containment was not compromised. Observations when the

protective cover was removed found streaks of rust on the underside of the cover, a

pronounced pattern of rust directly under the access plate, and water or signs of moisture

around most of the bolt lid holes and bolts. The elastomer O-ring seal on the bottom of

the protective cover was found to be completely intact and sealed against the top of the

cask lid.

lnspection Report No. 05000277 12010010

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In order to determine the root cause of the event, the licensee initiated a root cause

evaluation that included licensee and vendor personnel. The evaluation team concluded

that the mechanical cause of the helium leak was determined to be galvanic corrosion of

the main lid's outer seal due to the presence of moisture at the interface of the

aluminum-clad seal and the stainless steel cask body. The presence of the moisture at

the interface of the two dissimilar metals set up a galvanic cell that caused the aluminum

to corrode and allow helium to leak through the outer seal of the metal O-ring. The

helium leak test detection system performed its intended function.

The evaluation team identified two root causes for the event; both associated with the

performance of the protective cover that was intended to prevent water infiltration. The

first root cause was determined to be an inadequate design for sealing the access plate

in the protective cover. The second root cause was the lack of any verification of the

integrity of the water-tight cover. Based on the identified root causes, the licensee

developed two primary corrective actions and additional corrective actions to prevent

recurrence of the event. The two primary corrective actions, both intended to maintain

the integrity of the protective cover, include improving the design of the access plate and

developing a verification method for the integrity of the protective cover seals. The

licensee and cask vendor are currently working on a redesign of the protective cover and

developing a method for testing the integrity of the cover. Installation and testing for

Cask #1 is planned for mid-2012. Additional corrective actions include a change to the

torquing process for the lid bolts and ensuring that the access plate gasket and

protective cover O-ring are inspected at installation. These changes are incorporated in

the current procedure revision.

As part of the extent-of-condition review, the licensee has planned inspections for water

infiltration under the protective cover for the remaining casks that have been previously

loaded. Casks with a similar protective cover design (casks #2 - #9) are scheduled for

testing in August 201 1 followed by testing of the remaining casks (#10 - #52) that had

previous design changes of the protective covers. Replacement of covers is expected to

be based on the test results.

No findings of significance were identified.

c. Conclusions

The licensee conducted evaluations to determine the root cause of the helium-leak event

and concluded that the mechanical cause of the event was corrosion of the lid seal from

water infiltration through the protective cover. The licensee identified two root causes of

the event, both related to performance of the protective cover. Long-term corrective

actions to redesign the access plate to the protective cover and develop an enhanced

cask monitoring method are in the design stages by the licensee and cask vendor and

are expected to be completed and implemented in mid-2012. Short{erm corrective

actions including procedure changes for bolt torquing and verification steps for

confirming the integrity of the elastomer seals on the protective cover and protective

cover access plate have been implemented. As part of its extent of condition review, the

licensee has planned testing of the protective covers of the remaining loaded casks.

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5.0 ISFSI Routine Loading Campaign

a. Inspection Scope

The inspectors observed a routine ISFSI loading campaign from May 23,2011 to May

27,2011. The inspection consisted of field observations, review of license

documentation, and interviews with responsible personnel.

b. Observations and Findinos

The inspectors observed a portion of the cask preparation activities and movement of the

cask from the preparation area into the spent fuel pool. The inspectors then observed

the loading of spent fuel into the cask by the licensee's fuel handlers. The fuel

assemblies were properly identified and verified before being moved into the cask. The

licensee's reactor engineers did a further verification that the correct fuel assemblies had

been loaded by making a video recording of the fully-loaded cask and viewing the

recording for the identification numbers of the fuel assemblies. The inspectors also

viewed portions of the video recording to spot check that the correct spent fuel

assemblies were in the correct locations. The inspectors observed the placement of the

lid on the cask, the removal of the cask from the spent fuel pool and subsequent draining

of the cask and decontamination of the cask. Inspectors also observed placement of the

neutron shield, gamma shield and protective cover on the cask as well as part of the

overpressure system installation. Inspectors toured the ISFSI pad and the GentralAlarm

Station and viewed the alarm system for the cask overpressure system. All ISFSI

procedures and procedures for ISFSl-related activities were examined. The personnel

involved in the various ISFSI activities were interviewed and found to be knowledgeable

and experienced. The pre-job briefings were thorough and covered all aspects of the

activity to be performed.

No findings of significance were identified.

c. Conclusions

The licensee successfully performed the cask loading and storage on the ISFSI pad.

The licensee has a documented ISFSI program and trained personnel needed to meet

the criteria set forth in the Certificate of Compliance (CoC), Final Safety Analysis Report

(FSAR), and NRC regulations for an lSFSl.

Exit Meetinq Summarv

The inspection results were discussed with Garey Stathes, Site Manager and members of his

staff on May 27,2011, at the conclusion of on-site inspection activities.

ATTACHMENT: SUPPLEMENTAL INFORMATION

5 lnspection Report No. 05000277 12010010

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SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

Licensee

Jim Armstrong, Regulatory Assurance Manager

Jimmy Carter, Reactor Services Manager - Oyster Creek

Brian Cummings, Site Reactor Services Manager

Mark Dedrich, ISFSI Project Manager

Nick Dube, Reactor Services Supervisor

Dave Foss, Regulatory Assurance

Stuart Gray, Fuel Handling Director

Steve Hess, NOS Manager

Carl Kelly, Reactor Services Supervisor

Dan Kern, Lead Radiation Protection Technician

Brian Kozemchak, Work Group Supervisor

Pat Navin, Operations Director

Sarah Shewmaker, Reactor Engineer

Ron Smith, Regulatory Assurance

Garey Stathes, Plant Manager

Mike Summers, Reactor Services Supervisor

INSPECTION PROCEDURES USED

60855 Operation of an Independent Spent Fuel Storage Installation

60855.1 Operation of an Independent Spent Fuel Storage Installation at Operating Plants

ITEMS OPEN. CLOSED. AND DISCUSSED

None

LIST OF DOCUMENTS REVIEWED

50.59 Evaluation No. PB-2010-02-E

50.59 Screening No. PB-2010-019-5

7 2.48 Screening PB-201 1 -40-S

72.75 (g) Cask Event Report, December 1,2010

AR 01 131123 Report, ISFSI Cask #1 - Potential Helium Leak

AR 01201309 Report, ISFSI Cask #1 - Prepare for Storage

AR 01202466 Report, Site Align With ISFSI CoC and FSAR Review

AR 01207763 Report, lnspect ISFSI Casks 2-9 for Water Intrusion

AR01207767 Report, Inspect ISFSI Casks 10-20 forWater Intrusion

AR01207768 Report, lnspect ISFSI Casks 21-52 for Water Intrusion

AR01214782 Report, ISFSI Cask 45 Main Lid Binding On Guide Pins

AR 01219452 Report, ISFSI Cask TN-68-47 0 Degree Upper Trunnion Gauge

ECR PB 10-00061 000, Incorporate TN-68 Amendment 1

ECR PB 11-00099 000, Process Rev. 5 of TN-68 Dry Storage Cask FSAR

6 lnspection Report No. 0500027712010010

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ECR PB 11-00250 000, Removal of ISFSI Cask Alignment Pin for Lid Installation

FH-35, Control of Material Movement in the Fuel Pool

lR 1131123 ISFSI Cask #1 Helium Leakage - Root Cause

Letter TN to PB, Subject: Guidance for Rework of Damaged TN-68-47-0 Upper Trunnion

LS-AA-104-1001, 50.59 Review Coversheet Form

LS-AA-1 04-1 002, 50.59 Applicability Review Form

LS-AA-1 04-1004, 50.59 Evaluation Form PB-201 0-02-E

MA-AA-71 6-008, Foreign Material Exclusion Requirements

Micro ALARA Ptan 10-085, ISFSI Cask 1 (TN-68-1), Transport to/from pad, Troubleshoot,

Repair & Associated Support

Micro ALARA Plan 10-086, ISFSI Cask 1 (TN-68-1), Insert into SFP, Unload and/or repair main

lid seal

RT-W-071-901-2,ISFSI Cask and Storage Area Inspection

SF-150, Control of Cask Placement and Location on ISFSI Pad

SF-210, Preparation For An lndependent Spent Fuel Storage lnstallation Campaign

SF-220, Spent Fuel Casks TN-68-01 through TN-68-47 Loading and Transport Operations

SF-250, Varian 979-70 Helium Leak Detector Operations and Calibration

SF-290, Spent Fuel Cask Transport and Unloading Operations

SF-300, TN-68 Cask Spent FuelAssemblies Storage Selection and Document Requirements

SF-420, Radiation Protection Requirements During Spent Fuel Cask Loading and Transport

Operations

SF-490, Radiation Protection Requirements During Spent Fuel Cask Unloading and Transport

Operations

ST-H-071-804-2, ISFSI Casks TN-68-48 through TN-68-52 Surface Dose Rate and

Contamination

TN-68 Generic Technical Specifications

TN Drawing9T2-30-1

TN Drawing 972-70-2

LIST OF ACRONYMS USED

ADAMS Agency Wide Document Access and Management System

CFR Code of Federa.l Regulations

COC Certificate of Compliance

FSAR Final Safety Analysis Report

ISFSI Independent Spent Fuel Storage Installation

NRC Nuclear Regulatory Commission

lnspection Report No. 05000277 12010010

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