Text

Submittal of 10 CFR 71.95 Report on the 8-120B Cask
	ML15313A164
Person / Time
Site:	Mcguire, McGuire, 07109168
Issue date:	10/08/2015
From:	Capps S; Duke Energy Carolinas
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
	ES-CD-O-2015-006, MNS15-074
	Download: ML15313A164 (9)
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,D Vice President ENERGMcGuire Nuclear Station Duke Energy MG01VP 12700 Hagers Ferry Road Huntersville, NC 28078 October 8, 2015o:908545 Serial No: MNS15-074 f: 980.875.4809 Steven.Capps@duke-energy.com U. S. Nuclear Regulatory Commission 10 CFR 71.1 Washington, D.C. 20555-0001 10 CFR 71.95 ATTENTION:

Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards Duke Energy Carolinas, LLC (Duke Energy)

McGuire Nuclear Station (MNS), Units 1 and 2 Docket Numbers 50-369 and 50-3-70 Renewed License Numbers NPF-9 and NPF-17

SUBJECT:

10 CFR 71.95 Report on the 8-1 20B Cask for the McGuire Nuclear Station,.Units 1 and 2 Duke Energy hereby submits this report pursuant to 10 CFR 71.95(a)(3) regarding potential instances in which the conditions of the approved Certificate of Compliance (CofC) No. 9168 for the 8-120B cask may not have been observed in making certain shipments. During an NRC audit assessing the 10 CFR 71 program at EnergySolutions' Columbia, SC and Barnwell, SC facilities, the NRC inspection team identified that four out of eight 8-1 20B secondary lids did not comply with the approved 8-120B SAR drawings referenced in the current revision of the CofC.

The secondary lids were fabricated with a cladding tube inside the test port hole, but the tube is not shown on the SAR licensing drawings referenced by the CofC. The enclosed notification from the certificate holder (EnergySolutions) provides the information related to the condition as required by 10 CFR 71.95(a)(3). Althoughthis notification was developed by the certificate holder, it is applicable by use of the 8-120B cask at McGuire Nuclear Station on the following shipment dates: April 20, 2015 and July 6, 2015.

The presence of tubes in the secondary lid test ports was determined to have no safety consequence because the as-built test volumes with tubes installed in the secondary lids met the basis for the pre-shipment leak rate test hold time. All of the applicable 8-1 20B casks have been removed from service until CofC No. 9168 is amended to include the tube.

This letter contains no new regulatory commitments.

If you have any questions concerning this submittal, please contact Kay Crane, McGuire Regulatory Affairs at (980) 875-4306.

Enclosure :

EnergySolutions Report to the Nuclear Regulatory Commission www.duke-energy.com

United States Nuclear Regulatory Commission October 8, 2015 Page 2 xc:

Amy Gossett, Document Control Manager EnergySolutions Suite 100, Center Point II, 100 Center Point Circle Columbia, SC 29210 U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, Georgia 30303-1 257 G. E. Miller, Project Manager (MNS & CNS)

U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 8 G9A Rockville, MD 20852-2738 J. Zeiler NRC Senior Resident Inspector McGuire Nuclear Station

ENCLOSURE ENERGYSOLUTIONS REPORT TO THE NUCLEAR REGULATORY COMMISSION (6 pages)

ENERGYSOLUTIONS September 21, 2015 Letter ID: ES-CD-O-2015-006

Subject:

10 CFR 71.95 notification associated with the failure to observe Certificate of Compliance condition of the 8-120B secondary lid test port configuration.

Dear Valued Customer:

During a recent NRC audit performed September 8-10, 2015 assessing implementation of EnergySolutions' 10OCFR7 1 program at our Columbia, SC and Barnwell, SC facilities, the N-RC inspection team identified that four out of eight 8-120B secondary lids (Subject Secondary Lid ID numbers 8-120B-5, -6, -7 and -8) did not comply with approved 8-120B SAR drawings referenced in the current revision of the Certificate of Compliance 9168 (CoC).

The subject secondary lids were fabricated with a cladding tube inside the test port hole, but the tube is not shown on the SAR licensing drawings referenced by the CoC. Based on this, the conditions of approval in the CoC were not observed for any Type B shipments of radioactive material made in 8-120B casks utilizing the subject secondary lids. Subject secondary lids were entered into service between October - December, 2014 and have been used for a total of 52 shipments by licensees. The condition was determined not to have a safety consequence because the as-built test volumes with tubes installed in subject secondary lids met the basis for the pre-shipment leak rate test hold time.

Although, cladding tubes were part of the original NRC approved cask configuration in the old 8-120B secondary lids (used before August 31, 2013), they were inadvertently omitted in the new secondary lids design entered into service in September, 2013. Due to this condition, EnergySolutions suspended the use of the 8-1 20B casks with subject secondary lids. Further, EnergySolutions, on September 16, 2015, submitted a CoC amendment request to NRC requesting authorized usage of the subject secondary lids. EnergySolutions will retrofit all 8-120B secondary lids with the tube design at the earliest opportunity. We expect that the NRC will grant a new CoC (Rev.22) shortly aind the use of the affected 8-120B casks with subject secondary lids will resume. All our 8-120B users will be provided with a separate notification and an updated 8-120B cask book which will clarify the status of the affected CoC that the 8-1 20B casks can operate under.

Please see EnergySolutions' attached report containing the information required by 10 CFR 71.95. In the report, EnergySolutions describes the cause of the occurrence and provides information that supports that there is no safety significance associated with this condition.

We expect that the information required for individual users to make their own notifications is contained within this report. Reference to this report in individual user reports is appropriate, if you so choose.

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ENERGYSOLUTIONS We sincerely apologize for any inconvenience this issue may have caused within your organization. Our corrective actions as a result of this issue are intended to prevent recurrence of similar issues and to ensure the highest quality of products and services that we provide.

For additional details, please contact Aleksandr Gelfond at axgelfond@energysolutions.com or 803-587-9117.

Sincerely, Mark S. Lewis General Manager, Cask Logistics Logistics, Processing and Disposal EnergySolutions, LLC : EnergySolutions' Report associated with Failure to Observe Certificate of Compliance Conditions for the 8-120B Secondary Lid Test Port Configuration (4 pages) cc: Dan Shum (EnergySolutions) cc: Aleksandr Gelfond (EnergySolutions) 2

Failure to Observe Certificate of Compliance Conditions for the 8-120B Secondary Lid Test Port Configuration September 18, 2015

1) Abstract During a recent NRC inspection of EnergySolutions' facility in Columbia, SC, the inspection team identified that the secondary lids of four 8-120B casks' did not comply with the approved SAR drawings referenced by the latest revision of the Certificate of Compliance 9168 (CoC). The secondary lids on the subject casks were fabricated with a cladding tube inside the test port hole, but the tube is not shown on the SAR drawing referenced by the CoC. The conditions of approval in the CoC were therefore not observed for any shipments of Type B quantities of radioactive material made using the subject secondary lids. illustrates the secondary lid test port and tube configurations.

The purpose of the secondary lid test port tube is to isolate the pre-shipment test volume from the interspace between the two 3 1/4" thick plates that make up the secondary lid. The isolation of the test volume provided by the tube assures that the test volume does not exceed the limit on which the hold time for the pre-shipment leak rate test is based. However, if the free volume in the interspace between the plates is negligible, then the isolation function of the tube is not necessary.

The tube was shown as a design feature in the 8-120B SAR drawings referenced by Revision 17 of the CoC, and previous revisions, but the tube was not credited with any safety function in the SAR. The tube was inadvertently omitted when the lids were redesigned for operational enhancements in CoC Revision 19. The omission was identified by EnergySolutions' corrective action system while the subject lids were still in fabrication. A corrective action was assigned to measure the as-built test volumes, which included the void space between the thick plates since there were no tubes installed. The test volumes were found to exceed the volume basis for pre-shipment leak rate test hold time calculated in the SAR. The tubes were therefore installed, and the lids were placed on QA-hold using EnergySolutions' noncompliance procedure because they did not meet the lid configuration authorized by the CoC in effect at that time (i.e., CoC, Rev. 20). EnergySolutions subsequently made a determination that prior NRC authorization was not required (because the tubes had been part of the previous NRC-approved 8-1 20B cask design and were inadvertently omitted from the new secondary lid design), cleared the hold, and released the lids for use. The tubes were restored to the SAR drawings as part of a broader license amendment request submitted in May 2014, but the request was withdrawn for unrelated reasons. A new license amendment request submitted to the NRC on 9/16/2015 reintroduces the tubes to the secondary lid design.

The presence of the tubes in the subject secondary lid test ports has no safety consequence because the as-built test volume meets the basis for the pre-shipment leak rate test hold time.

' Secondary lid numbers 8-120B-5, -6, -7, and -8.

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2) Narrative Description of the Event a) Status of Components All of the 8-1 20B casks operating with the secondary lids that have the tube installed in the test port (i.e., secondary lid numbers 8-120B-5, -6, -7, and -8) have been removed from service until CoC No. 9168 is amended to include the tube.

b) Dates of Occurrences Casks with the secondary lids that have the tube installed in the test port (i.e., secondary lid numbers 8-120B-5, -6, -7, and -8) were entered into service between October 2014 and December 2014 and have been used for a total of 52 Type B shipments (by all licensees).

c) Cause of Error EnergySolutions cleared the hold and released the subject secondary lids for use, believing that prior NRC authorization was not required because the tubes had been part of the previously NRC-approved 8-1 20B cask design and were inadvertently omitted from the new secondary lid design.

d) Failure Mode, Mechanism, and Effects Not applicable.

e) Systems or Secondary Functions Affected Not applicable.

f) Method of Discovery of the Error The error was identified by the NRC inspection team during an audit at the EnergySolutions' facility in Columbia, SC.

3) Assessment of Safety Consequences The presence of the tubes in the subject secondary lid test ports has no safety consequence because the as-built test volume meets the basis for the pre-shipment leak rate test hold time.

The secondary lid test port configuration of the subject lids is similar to the design previously authorized for use prior to CoC Revision 19.

4) Planned Corrective Actions The following corrective actions are planned by EnergySolutions:

EnergySolutions has removed 8-1 20B casks with the secondary lids that have the tube installed in the test port (i.e., secondary lid numbers 8-120B-5, -6, -7, and -8) from service until authorized to resume their use.

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EnergySolutions has evaluated the condition for reportability under 10 CFR 71.95 and has concluded that it is reportable.

EnergySolutions will notify the licensees (cask users) that have made shipments using the 8-120B casks with the affected secondary lids and advise them to evaluate reportability under 10 CFR 71.95.

EnergySolutions has prepared and submitted an application to NRC to amend CoC No. 9168 to include the test port tube in the four subject secondary lids as an authorized configuration.

EnergySolutions will perform an apparent cause analysis and identify additional corrective actions to prevent recurrence.

5) Previous Similar Events Involving the 8-120B No previous similar events have been identified.

6) Contact for Additional Information Dan Shrum EnergySolutions Senior Vice President, Regulatory Affairs (801) 649-2109

7) Extent of Exposure of Individuals to Radiation or Radioactive Materials None.

3 Secondary Lid Test Port with Cladding Tube (subject secondary lids)

Secondary Lid Test Port without Cladding Tube (current CoC configuration) 4