ML20134H323

Final Response to FOIA Request for Documents.Records in App G Encl & Available in Pdr.App H Records Being Withheld in Part (Ref FOIA Exemption 6)

ML20134H323
Person / Time
Issue date:	10/30/1996
From:	Racquel Powell NRC OFFICE OF ADMINISTRATION (ADM)
To:	Dums D CITIZENS' UTILITY BOARD
Shared Package
ML20134H325	List: IA-96-322, Forwards Partially Withheld Incoming & Draft Response to Shillinglaw 960620 Ltr Re Green Ticket on VSC-24 ML20134H323 ML20134H341
References
FOIA-96-322 NUDOCS 9611140057
Download: ML20134H323 (4)

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U.S. NUCLEAR REEULATORY COMMISSION NRC FOIA REQUEST NUMBER (S)

FOIA 322

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RESPONSE TO FREEDOM OF RESPONSE TYPE x 1 FINAL (6th)l l PARTIAL INFORMATION ACT (FOIA) REQUEST DATE ees.e DOCKET NUMBER (S)(if applicablef REQUESTE R Dennis Dums PART 1.-AGENCY RECORDS RELEASED OR NOT LOCATED (See checkedboxes)

No agency records subject to the request have been located.

No additional agency records subject to the request have been located.

Requested records are available through another public distribution program. See Comments section, Agency records subject to the request that are identified in Appendix (es) are already available for public inspection and copying at the NRC Public Document Room. 2120 L Street, N.W., Washington. DC.

Agency records subject to the request that are identified in Appendix (es) are being made available for public inspection and copying ct the NRC Public Document Room,2120 L Street. N.W., Washington, DC,in a folder under this FOIA number.

The nonproprietary version of the proposal (s) that you agreed to accept in a telephone conversation with a member of my staff is now being made available for public inspection and copying at the N RC Public Document Room,2120 L Street, N.W., Washington, DC, in a folder under this FOI A number.

Agency records subject to the request that are identified in Appendix (es) may be inspected and copied at the NRC Local Public Document Roorn identified in the Comments section.

Enclosed is inforrn& tion on how you may obtain access to and the charges for copymg records located at the NRC Public Document Room,2120 L Street, N.W., Washington, DC.

y Agency recnrds subject to the request are enclosed.

Records subject to the request have been referred to another Federal agency (ies) for review and direct response to you.

y Fees (NONE)

You will be billed by the NRC for fees totaling $

You will receive a refund from the NRC in the amount of $

In viiw of N RC's response to this request, no further action is being taken on appeal letter dated , No.

PART 11. A-INFORMATION WITHHELD FROM PUBLIC DISCLOSURE Certiin information in *he requested records is being withheld from public disclosure pursuant to the exemptions described in and for the reasons stated in Part it, B, C, and D. Any released portions of the documents for which only part of the record is being withheld are being made available for public  ;

)( inspection and copying in the NRC Public Docurmt Room,2120 L Street, N.W., We;hington, DC in a folder under this FOI A number. l COMMENTS

• The records identified on enclosed Appendices G and H are the remaining records responsive to your request. A copy of the Appendix G record and the releasable portions of the Appendix H record are enclosed.

This completes NRC's action on your request.

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r - n St IVISION O FRE OFI FORMATION AND PUBLICATIONS SE RVICES

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FOBQ NUMeEWis) DCTE RESPONSE TO FREEDOM OF INFORMATION ACT (FOIA) REQUEST FOIA 322 fg '3 ,>

(CONTINUATION) l PART 11.5- APPUCABLE EXEMPTIONS l Records subject to the request that are described in the enclosed Appendix (est H are being withheld in their entirety or in part under the l Exernption No.(s) and for the reason (s) given below pursuant to

1. The withheld mformation is property classified pursuant to Executive Order. (Exemption 1)

3. The wrthheld information relates so6ely to the mternal personnel rules and procedures of NRC. (Exemption 2) l l3. The withheld mformation is specifically exempted from pubhc disclosure by statute indicated. (Exemption 3)

Sections 141 145 of the Atomic Energy Act, which prohibits the disclosure of Restricted Date or Formerly Restricted Data (42 U.S.C. 21612165).

Section 147 of the Atomic Energy Act, which prohibits the disclosure of Unclassified Safeguards Information (42 U.S.C. 2167).

. The withheld information se a trade secret or commercial or fmancial information that is bemg withheld for the reason (s) indicated. (Exemption 4)

The information is conssdered to be confidential busmese fpropnetaryl mformation, The information is cons +dered to be propnetary information pursuant to 10 CFR 2.790(d)(1).

The information was submitted and received in confidence pursuant to 10 CFR 2.790tdH2)

5. The withheld mformation consists of mteragency or mtraagency records that are not available through discovery dunng litigation (Exemption 5). Applicable Privilege:

Dehberative Process: Disclosure of predecisional mformation would tend"to inn 54t the open and frank exchange'of idessisse~ntsal to the dehberative process.

Where records are withheld m their entirety. the facts are mentricably mtertwmed with the predeciseones mformation. There also are no reasonably segregable f actual portions because the release of the facts woued permit an indirect mquiry into the predecisional process of the agency Attomey work product pnvilege IDocument prepared by an attorney m contemplation of htigation i Attorney client privilege. (Confidential communications between an attorney and his/her chent.)

y 6. The withheld mformation is exempted from pubhc disclosure because its disclosure would result m a clearly unwarranted mvasion of personal pnvecy (Exemption 6)

17. The wahheld mformation consists of records compiled for law enforcement p rposes and is be Disclosure could reasonably be expected to mterfere with an enforcement reoceedmg because it could reveal the scope, direction, and focus of enforcement efforts. and thus could possibly allow recipients to take actiren to shield potential wrongdomg or a violation of N RC requirements from investigators. (Exemption 7 (A))

Disclosure would constitute an unwarranted mvasion of personal privacy. (Exemption 7(C))

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OTHER The mformation consists of names of mdividuals and othe: information the desclosure of which could reasonably be enoected to reveal identities of confederstial sources. (Exemption 7 (01) 1

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PART 11. C-DENYING OFFICIALS Pursuant to 10 CFR 9.25tb) and/or 9.25(c) of the U S. Nuclear Regulatory Commission regulations, et has been determmed that the information withheld is exempt from pro-duction or disclosure, and that its production or disclosure is contrary to the pubhc interest. The persons responsible for the denia? are those officials identified below as denying officicis cnd the Director, Division of Freedom of information and Pubhcations Services. Office of Admmistration, for any denials that may be appealed to the Executive Director for Operations (EDOL DENYING OFFICIAL TITLE / OFFICE RECORDS DENIED APPELLATE OFFICIAL EDO SECRETAM IG Frank J. Miraglia Actina Director. NRR Aco. H X l

t PART 11. D- APPEAL RIGHTS I

l The damal by each denying official identified in Part it.C may be appealed to the Appellate Official identified there. Any such appeal must be made m writing within 30 days of receipt of thb response. Appeals must be addres;..d, as appropriate, to the Executive Director for Operations, to the Secretary of the Commission, or to the Inspector General. U.S. Nuclear Regulatory Commission, Washington, DC 20555, and should clearly state on the envelope and in the letter that it is an " Appeal from an initial FOl A Decision."

NRC FORM 464 (Pert 2) (1-91) U.S. NUCLEAR REGULATORY COMMISSION

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Re FOIA-96-322 APPENDIX G RECORDS MAINTAINED IN THE PDR UNDER THE ABOVE REQUEST NUMBER NUMBER DATE DESCRIPTION /PAGES

1. 7/12/96 Memo to NRR Project Directors from William Reckley, subject

Bulletin 96-04, " Chemical, Galvanic, or Other Reactions in Spent Fuel Storage and Transportation Casks,"

(11 pgs.).

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I Re: FOIA-96-322 APPENDIX H DOCUMENTS BEING RELEASED IN PART l NUMBER DATE DESCRIPTION / EXEMPTION 1

l 1. 7/25/96 E-Mail from W. Reckley to M. Bailey and E. Leeds, subject: " Green Ticket on VSC-24," (1 pg.) - RELEASE; with '

attachment: Letter to Chairman Jackson from F. Shillinglaw, (3 pgs.) -

PARTIALLY RELEASED, EX. 6; and Proposed Letter to F. Sh1111nglaw from W.

Russell, (4 pga.) - PARTIALLY RELEASED, l EX. 6.  ;

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CITIZENS' UTILITY BOARD 16 N. Carroll St., Suite 300 Madison, WI 53703 - (608)251-3322 FAX (608)2517609 EREEDOM 0F INFORMATION August 5, 1996 ACT REQUEST Mr. Russell Powell f0.TA-fh 0 W Branch Chief FOIA/LPDR Nuclear Regulatory Commission

/(ecd 9-O7[ I Washington, D.C. l 20555 i

Re: Freedom of Information Act Request

Dear Mr. Powell:

l Pursuant to the Freedom of Information Act, 5 U.S.C. 522, as amended and 10 C.F.R. Part 9.41, the Wisconsin Citizens' Utility 1 Board (CUB) requests the following documents: )

1. Please provide any and all docaments that make a specific i reference to the event at the Point Beach nuclear power plant, Dockets 50-266 and 50-301, involving a gaseous ignition l incident during the welding of a spent fuel cask. This event was identified by the NRC in Preliminary Notification of Event or Unusual Occurrence PNO-III-96-033 on May 28, 1996;

2. Please provide any and all documents that address the generation of explosive gases during any phase of operation of the VSC-24 system;

3. Please provide

• any and all documents that address the ignition of explosive gases during any phase of operation of the VSC-24 system.

On June 4, 1996 CUB submitted a FOIA request to the NRC requesting-documents responsive to items 1-3. The NRC completed its response to CUB's June 4, 1996 FOIA, identified by the NRC as FOIA-96-244/ June 10, 1996, on July 25, 1996. CUB is re-submitting its FOIA request for items 1-3 to obtain documents in the agencies possession for the period of time following the date the NRC received CUB's June 4, 1996 FOIA to the date the NRC receives this FOIA request.

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4. Please provide any and all documents that address increased i- neutron multiplication in the fuel in a cask because of boron .

precipitation from a chemical reaction among the borated water

! and cask-materials. 3

5. Please provide any and all documents that address the effect  :

of a precipitate formed by a chemical reaction of zine with .

acidic borated water from a spent fuel pool on fuel cladding

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6. Please provide any and all documents that address the effect of a precipitate formed by a chemical reaction of zine with acidic - borated water from a spent fuel pool on the heat '

transfer characteristics of a VSC dry storage cask. ,

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7. Please provide any and all documents that address the behavior l of a precipitate formed by a chemical reaction of zinc with  ;

l acidic borated water from a spent fuel pool under long-term ,

l exposure to neutron and gamma radiation.' l

? i l 8. Please provide any and all documents that address the behavior

! of a precipitate formed by a chemical reaction of zine with acidic borated water from a spent fuel pool under high j temperatures.. l

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9. Please provide any and all documents that address the effect l of a zine reaction with the acidic borated water from a spent )

fuel pool on the characteristics of MSB anti-corrosion coatings.

10. -Please provide any and all documents that address-the offect of a zinc reaction with the acidic borated water from a spent fuel pool on the retrievability of spent fuel.

11. Please provide any and all documents that address the effect of a zinc reaction with the acidic borated water from a spent fuel poor on the reactor coolant system.

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! For purposes of this request, please consider " documents" to l include reports, studies, test results, correspondence, memoranda, l meeting notes, meeting minutes, working papers, graphs, charts, diagrams, notes and summaries of conversations and interviews, l computer records, and any other form of written communications including internal NRC memoranda.

l Pursuant to and in compliance with 10 C.F.R. 9.41 of the agency's regulations and 5 U.S.C. 552 governing requests for waiver .

of fees, CUB puts forth the following information.

! CUB was incorporated pursuant to Chapter 181, 1979, of the l

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l Wisconsin Statutes. CUB is exempt from Federal income tax under 4 l Section 501(c)(4) of the Internal Revenue Code. CUB is also exempt  !

from Wisconsin franchise tax.

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The restricted fund (public interest fund) is exempt from Federal income tax under Section 501(c)(3) of the Internal Revenue Code. The fund is also exempt from Wisconsin income taxes. The

re'stricted fund (public interest fund) was established on February l

1, 1981, and reorganized on April 28, 1986 to correspond to the new l atructure of the CUB. The fund engages in charitable, scientific, j literary and educational activities on behalf of CUB.

CUB has 20,000 members who are residential ratepayers in l Wisconsin. CUB represents the more than two million residential l ratepayers in the state. CUB's purpose continues to be the statutory purpose set forth under sec. 199.02, Wis. Stats.:

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...to promote the health, welfare and prosperity of all the l

citizens of this state by ensuring effective and democratic representation of individual farmers and other individual residential utility consumers before regulatory agencies, the legislature uad other public bodies and by providing for consumer educ2 tion on utility service costs and on benefits l and methods of energy conservation.

i l CUB seeks the requested information to become informed of -the causes, consequences,. and remedies of and for an incident which took place on May 28, 1996 involving the use of the VSC-24 storage system for spent nuclear fuel.

CUB intends to use the information to assist in its l participation in any proceedings before the NRC, before state l regulatory agencies, and as part of CUB's ongoing ef fort to educate j the_public on nuclear waste storage issues in Wisconsin.

j The information sought, is not, to the best of our knowledge, in the public domain. The general public in Wisconsin has displayed great interest in nuclear waste issues and have a direct i interest in NRC actions regarding the VSC-24 dry cask storage system.

CUB has demonstrated its ability and commitment to inform the public on all important nuclear waste storage issues in Wisconsin.

CUB provides-this information free of charge through newsletters, educational pamphlets, and correspondence to its members, other ,

- residential ratepayers, legislators, and policy makers, and has )

neither a commercial nor a private interest in the agency records  !

sought.

Under the amended fee waiver standard, CUB is clearly entitled I I

to a full waiver of all search, review and duplication fees. This standard calls for such a waiver, "if disclosure of the information l l 1s in the public interest because it is likely to contribute j significantly to the public understanding of the operation or l

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activities of the government and is not primarily in the commercial interest of the requester." 5 U.S.C. 552 (1)(4)( A)(iii) .

In . light of the foregoing, CUB meets this standard on its face. CUB has no commercial interest in this matter, but rather seeks this information to help the general public better understand l the role of government in regulating the nuclear industry's ,

radioactive waste storage activities.

For the reasons cited above, CUB's request falls squarely l within the Congressional intent in enacting the Freedom of

! Information Act and the fee waiver provision. CUB, therefore, asks that the NRC grant a full fee waiver for this FOIA request.

Thank you for your anticipated cooperation. If you have any questions in regards to this request, please feel free to contact me at your earliest convenience. Please contact me before acquiring and sending the requested information if the fee waiver is not applied.

Sincerelyh Dennis Dums

~v-Research Director i

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- l W ur ug?* UNITED STATES l 3- g, j . j !M 'j NUCLEAR REGULATORY COMMISSION g WASHINGTON, D.C. 20066 0001

. . . . . ** July 12, 1996 l MEMORANDUM TO: NRR Project Directors THRU: Gail H. Marcus, Director M hfu%

Project Directorate III-3 Division of Reactor Projects III/IV Office of Nuc act r Regulation FRON:

Q William D. keck ey,

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Project Directorate III-3 ( MHager Division of Reactor Projects /IV Office of Nuclear Reactor Regulation

SUBJECT:

BULLETIN 96-04, " CHEMICAL, GALVANIC, OR OTHER REACTIONS IN SPENT FUEL STORAGE AND TRANSPORTATION CASKS," (MPA X604)

NRC Bulletin 96-04 (attached) instructs power reactor licensees with independent spent fuel storage installations (ISFSIs), vendors of spent fuel l storage or transportation casks, and holders of certificates of compliance for i

spent fuel storage or transportation casks to provide information related to

! material compatibility of storage casks or transportation casks with the environments that they may encounter. The bulletin was issued in response to an event at Point Beach in which a enemical reaction between a coating on a storage. cask and the borated water iri the spent fuel pool resulted in the l production of hydrogen. A hydrogen ignition occurred when licensee personnel initiated welding of the cask lid.

The bulletin was sent to all holders of operating licenses or construction permits for nuclear power reactors. However, only those licensees with an ext.tir.9 ISFSI or holders of certificates of compliance for transportation casks need to respond to the bulletin. A list of plants from which a response is expected is provided below:

! Calvert Cliffs Robinson

Oconee Surry '

i Arkansas Nuclear One Davis-Besse Palisades Point Beach Prairie Island Licensees that do not have an ISFSI or transport cask certificate of compliance should not submit any response to the bulletin (i.e., they should treat the bulletin the same as an information notice). This includes those  !

licensees that plan to construct an ISFSI but have not yet taken delivery of 1 i the storage casks. If a licensee has questions on whether or not they need to respond to the bulletin, please have Project Managers contact me at 415-1314 or email-WDR.

1 CONTACT: William D. Reckley, NRR (301) 415-1314 j a on 1.7n ? s-g - kh

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NRR PDs i

! MPA TACs have been opened for the plants listed above. If a licensee submits

!' a response for any other plant, contact the NRR LPM and, if necessary, TACs

{ will be created. Upon receiving a submittal from an " action addressee"

licensee, Project Managers should update WISP to reflect the submittal and l- ensure that the NRR LPM is provided a copy of the submittal. Submittals will 3 be evaluated.by BMSS and NRR technical staff. Requests for additional l information or other correspondence will be coordinated by the NRR LPM and

) provided to the appropriate Project Manager for issuance.

! Project Mangers may direct any questions regarding the bulletin to me at

! 415-1314/email-WDR or Marissa Bailey of MSS at 415-8531/email-agb.

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Attachment:

As stated.

cc: R. Zimmerman S. Varga

' J. Roe

! DRPE/DRPW Deputy Directors ,

j DRPE/DRPW Project Managers

! M. Boyle, TA, DRPE C. Carpenter, TA, DRPW Distribution: e//

Central File PDIII-3 Reading h [/ O M. Chaney E. Leeds,100$$

M. Miley, NMSS P. Eng, NMSS W. Travers, NMSS C. Haughney, NMSS DOCUMENT NAME: G:\ DRY-CASK \8UL9604.M0 v i . ,y .e ei. 4 i. me m e. 6 : c - c.,y ww.ve i - c.,y wem .ad n - N. ,y

• - see >revious concurrence OFFICE PD33:LA lC PD33:PM lC DRPE:TA DRPW:TA l PD33:D l NAME DFoster-Curseen* WReckleW% MBoyle* CCarpenter* GMarcus C-WT DATE 07/11/96 07/lA/96 07/11/96 07/12/96 07/r2/96 0FFICIAL RECORD COPY

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• OMB No. 3150-0011 NRCB 96-04

UNITED STATES 4

NUCLEAR REGULATORY C0fmISSION OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, D.C. 20555

July 5, 1996 i .

l NRC BULLETIN 96-04: CHEMICAL, GALVANIC, OR OTHER REACTIONS IN SPENT FUEL

, STORAGE AND TRANSPORTATION CASKS i, Addressees This bulletin is being sent to:

! All holders of operating licenses or construction permits for 4 nuclear power reactors.

k All holders of, and applicants for, certificates of compliance for l transportation casks for commercial spent fuel.

All holders of, and applicants for, certificates of compliance for storage casks for commercial spent fuel.

All vendors of storage and transportation casks for commercial spent fuel.

All registered users of transportation casks for commercial spent fuel. j It is expected that all recipients will review the information for annli m bility to their facilities and consider actions as appropriate to avoid pr'oblems similar to those discussed here. However, action is only requested ,

from those addressees who are licensees with independent spent fuel storage '

installations, vendors of spent fuel storage or transportation casks, and holders of certificates of compliance for spent fuel storage or transportation casks (" action addressees").

Purpose The U.S. Nuclear Regulatory Commission (NRC) is issuing this bulletin to:

(1) notify addressees about the potential for chemical, galvanic, or other reactions among the materials of a spent fuel storage or transportation cask, its contents, and the environments the cask may encounter during use, that may produce adverse conditions in cask loading /unlot. ding / handling operations or degrade the integrity and performance of the cask; (2) request that all action addressees implement the actions described herein; and (3) require that all action addressees provide, to NRC, written responses to this bulletin, relating to implementation of the requested actions. This bulletin also

- 9607020241

NRCB 96-04 July 5, 1996 Page 2 of 9 i:

requires that certain information on the subject matter of this bulletin be submitted to NRC.

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Background

i j On May 31, 1996, NRC Information Notice 96-34 was issued as notification of a i hydrogen gas ignition event that occurred during the welding of the shield lid on a spent fuel storage cask at the Point Beach Nuclear Plant.

j Description of Circumstances 1

( On May 28, 1996, a hydrogen gas ignition occurred during the welding of the

! shield lid on a ventilated storage cask (VSC-24) multi-assembly sealed basket

(MSB). The gas ignition displaced the shield lid (weighing about 2898 i kilograms [6390 pounds]), leaving it in place but tipped at a slight angle, j with one edge about 7.6 centimeters [3 inches) higher than normal.

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l The loaded VSC-24 multi-assembly transfer cask (MTC), a shielded lifting j- device used to transfer the MSB loaded with spent fuel to the ventilated

! concrete cask, had been placed in the cask. decontamination work area in the

! auxil,iary building. Approximately 114 liters [30 gallons) of borated spent fuel pool water had been drained from the MSB to facilitate welding of the shield lid, creating an air space below the lid. The hydrogen gas ignition occurred during the initiation of the shield lid welding, approximately 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> after the loaded MTC had been removed from the spent fuel storage pool.

After the event, gas and water s'amples collected from the MSB internals showed detect &ble levels of hydrogen both in the air space beneath the shield lid and dissolved in the MSB water. The licensee then continuously purged the air space beneath the lid with nitrogen to prevent the accumulation of combustible gases and returned the shield lid to its original position.

The MSS was then fully flooded to eliminate the air space under the shield lid and returned to the spent fuel storage pool. On removal of the shield lid, the licensee observed a white, foam-like substance under the shield lid. Most of this substance floated to the top of the pool; however, some remained below the surface of the water. Samples of this substance were taken to Argonne National Laboratory for analysis.

The licensee unloaded the spent fuel assemblies and placed them in the spent fuel pool storage racks. A visual examination of the MSB, the MTC, and the spent fuel assemblies showed no evidence of damage as a result of the combustible gas ignition.

The unloaded MTC/MSB was subsequently moved back to the decontamination work ,

area for further inspection as part of the licensee's investigation of the I combustible gas ignition. At the decontamination work area, the MSB remained filled with borated spent fuel pool water for several days. Hydrogen continued to be generated during that time, as evidenced by the effervescence off the MSB shell and fuel grid.

j NRCB 96-04 l~. .

July 5, 1996 j Page 3 of 9 l The licensee investigation determined that the source of hydrogen was

' oxidation of zine in the Carbo Zine 11 coating (used as a coating to prevent corrosion) of the MS8 when in contact with the borated water in the spent fuel pool. The zinc reacted chemically with the acidic borated water from the

.i spent fuel storage pool to produce hydrogen, and zine oxide and hydroxide.

3 The foam-like substance was determined to be a mixture of a precipitate formed 1 j by the reaction, residual soap used during decontamination of the MSB, and a1r.

i On June 3,1996, Confirmatory Action Letters (CALs) were issued to licensees i using the V5C-24 c.ask (i.e., Arkansas Nuclear One, Palisades Nuclear

} Generating Plant, and Point Beach Nuclear Plant . The CALs confirmed a j commitment, made by each of the three licensees)to NRC, that prior to loading i or unloading a VSC-24 cask wi'.h spent fuel, or placing a VSC-24 cask into the spent fuel p,ool, the licensees will: (1) assess the potential for the j generation and ignition of explosive gases during all phases of operation of

! the VSC-24 system; (2) have compensatory actions in place to minimize the l potential for the generation and ignition of explosive gases; and (3) have i procedures in place to respond in the event of a gas ignition and the l

applicable personnel trained and briefed accordingly.

! Suppiements- to each of the June 3,1996, CALs were subsequently issued on i June 21 and June 27, 1996, to confirm a further commitment, made by each of 1 the three licensees to NRC, that the licensees will: (1) provide the required j ,

response specified in the staff forthcoming generic communication on the Point i Beach VSC-24 event (i.e., this bulletin); and (2) refrain from loading or

. unloading a VSC-24 cask, or placing a VSC-24 cask into the spent fuel pool, pending staff review and acceptance of the response and verification of any q subsequent actions taken in response to this bulletin.

Discussion

An EC Aug. ar.ted Inspection Team (AIT) was formed and sent to the site on

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Nay 29, 1996, to examine the circumstances surrounding the event. The AIT Charter consisted of evaluations of the licensee response to the event, including the radiation protection consequences of the event to both the plant staff and the general public, the effectiveness of the licensee root-cause investigation, and determination of any potential generic implications of the event. The findings of the AIT are summarized below. Details of the AIT 1 findings are documented in Report Nos. 50-266/96005 and 50-301/96005. l The AIT agrees with the licensee that the hydrogen was formed by a chemical reaction among the Carbo Zine 11 coating and the borated pool water.

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' NRCB 96-04 1- '

July 5, 1996 Page 4 of 9 The licensee believes that its internal processes associated with the design, design review, design specifications, and the independent review of the VSC-24 cask were deficient in that they did not recognize that the chemical reaction of the Carbo Zine 11 coating with borated water would result in the production of hydrogen.

The licensee had several opportunities to identify the generation of gas inside the MS8 during previous cask loading operations, because of several noted abnormalities. However. the abnormalities were not documented and were not viewed collectively. This is of particular concern because in at least one case the licensee had indications that the gas being produced may have been combustible.

.The generic implications of the event extend beyond the use of the VSC-24 system. The AIT recommends that the adequacy of the chemical compatibility studies conducted during design reviews for all dry cask storage designs and facility environments should be reviewed. In addition, the suitability of Carbo Zinc 11 and other similar coatings used in nuclear applications, where there is the potential for exposure to boric acid, should be reviewed.

The gas ignition caused no injuries, no radiological releases, and no apparent damage to the spent fuel, storage cask, or the reactor facility itself. ,

However, the event has raised some generic issues pertaining to both spent  !

fuel storag'e and transportation casks. These generic issues extend to spent fuel transportation casks because transportation casks have designs similar to storage casks. Also, the current trend in the industry is to pursue licensing of dual-purpose, storage / transport cask designs.

Provisions for material suitability exist .in both 10 CFR Part 71 and Part 72.

iiutwithstanoing, the event at Point Beach suggests that the VSC-24 vendor and licensees did not adequately consider material reactions, and material compatibility with possible environments, in the design and design review of the VSC-24 cask. Also, NRC did not fully consider material reactions and material compatibility in its licensing review of the VSC-24 cask and other storage and transportation casks.

Two specific concerns or issues, one short-term and one long-term, arise from the event at Point 8each. The short-term concern is that combustible gases generated by material reactions may create hazardous conditions while loading or unloading a cask. The reactions, which form the combustible gases and precipitate, would not continue after the loaded casks are drained, evacuated, and back-filled with inert helium gas. Thus, the reactions would not continue while the cask and spent fuel are in the dry storage or transportation mode.

However, the reactions could resume when the cask is reflooded prior to unloading, and therefore, need to be considered in cask unloading operations.

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• NRCB 96-04

! July 5, 1996 j Page 5 of g

' The long-term concern is that any remaining product of these . reactions, e.g., I the precipitate, may degrade the structural integrity and adversely impact the )

rett imbility of the stored spent fuel. Degradation of the fuel structural integrity is not expected to present an immediate health or safety concern.

However, the overall requirements specified in 10 CFR 72.122 for spent fuel storage casks include protection of the fuel cladding from degradation and ready retrieval of the spent fuel. The staff, based on available information, does not anticipate any impact on the continued safe confinement of spent nuclear fuel in existing dry storage installations.

Based on available information and operational experience, it appears that the VSC-24 design is the system most susceptible to hydrogen gas generation. This is due to the VSC-24 relatively large use of carbon steel and anti-corrosion coatings (i.e., Carbo Zinc 11). Other licensed - cer"fied cask designs are primarily constructed of stainless steel, and e't'd . no or limited quantities of anti-corrosion coatir.gs. Over 75 non-v5C-24 storage casks have been loaded, and spent fuel transportation casks have been in use for over 20 years. Operational experienca with these casks has not evidenced any problems with material reactions, material incompatibility, and combustible gas generation during loading or unloading. Nevertheless, since the licensing review did not evaluate this issue, this bulletin is intended to request information to confirm that chemical, galvanic, or other reactions are not a concern for other storage and transportation cask designs.

. Rtggested Actions Actio3 4ddressees are requested to take the following actions:

1. Address the following items relating to the susceptibility of the spent fuel storage or transportation cask design to chemical, galvanic, or other reactions:

(a) Review the cask materials, including coatings, lubricants, and cleaning agents, to determine whether chemical, galvanic, or other reactions among the materials, contents, and environment can occur during any phase of loading, unloading, handling, storage, and transportation. Consideration should be given to all environments that may be encountered under normal, off-normal, or accident conditions.

(b) Evaluate the effects of any identified reactions to determine if any adverse conditions could result during cask operations, including loading and unloading. Consideration should be given, but not limited, to:

(1) generation of flammable or explosive quantities of hydrogen or other combustible gases; and (11) increased neutron multiplication in the fuel in a cask because of boron precipitation from a chemical reaction among the borated water and cask materials.

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NRCB 96-04  !

j July 5, 1996 i

Page 6 of 9 l (c) Review current cask operating procedures to determine if adequate i

controls and procedures are in place to minimize hazardous conditions that may be created by any identified reactions.

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Evaluate the effects of any identified reactions to determine if 4

(d) 3 i

their reaction products could reduce the overall integrity of the cask or its contents during storage or transportation. Determine <

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if the reaction products could adversely affect the cask ability 1 to maintain the structural integrity and retrievability of the  !

i speni. fuel throughout the ters of the license or to transport fuel safely. Consideration should be given, but not limited, to i '

i (1) changes in cask and fuel cladding thermal properties, such  ;

i as emissivity; l

( .

1 (ii) binding of mechanical surfaces, especially fuel-to-basket j clearances; and i

(iii) degradation of any safety components, either caused directly by the effects of the reactions, or by the effects of the reactions combined with the effects of long-term exposure of

the materials to neutron and gamma radiation, high temperatures, or other possible conditions.

F . 2. For storage casks currently loaded with spent fuel, determine the i extent, if any, of the chemical, galvanic, or other reactions that have >

l occurred, and the effect of these reactions on the cask ability to

! maintain the structural integrity and retrievability of the spent fuel

throughout the term of the license.

l In addition to the items above, the vendor and users of the VSC-24 spent fuel It: a g u A ( L .. Huclear Corporation, Arkansas Nuclear One, Palisades Nuclear Generating Plant, and Point Beach Nuclear Plant) are requested to take the following actions:

i

! 3. Evaluate the effects of the reaction among Carbo Zinc 11 (or other' i

equivalent coating used) and the water environments the cask may

encounter. Show that the ability of the cask to maintain the structural i integrity and retrievability of the spent fuel over-a 20-year period has i

not been adversely affected by the formation of precipitate, or by any other effects of the reaction. Justify the continued use of VSC-24 i storage casks already loaded with spent fuel. In this evaluation, i

consideration should be given, but not limited, to:

[ (a) the effect of the precipitate on fuel cladding integrity; (b) the effect of the precipitate on the heat transfer characteristics of the cask; and i

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NRCB 96-04 July 5, 1996 i

Page 7 of 9 i (c) behavior of the precipitate under long-ttre exposure to neutron and gamma radiation, high temperatures, and other possible l conditions.

4. Evaluate the procedures for unloading the cask to consider the likely presence of hydrogen gas or precipitate inside the MSB and the possible adverse effects of the hydrogen gas or precipitate on cask handling and i performance. Inform the NRC of any changes made to the unloading i procedures.

Reauired Response i-Pursuant to 10 CFR 2.204, 10 #FR 71.39, and 10 CFR 72.44(b)(3), in order to

! determine whether any license or certificate ~should be modified, suspended, or revoked, or other action taken, within 45 days of the date of this bulletin, i action addressees are required to submit a written response indicating whether j the addressee will implement the requested actions.

I j 1. If the addressee intends to implement the requested actions:

j (1) The 45-day response should include a report confirming completion

of the actions requested in Items 1(a), 1(b), and 1(c), above, and

[ a schedule for completing implementation of the actions requested

! in Items 1(d) and 2, and if applicable, Items 3 and 4, above. ,

! (ii) Within 30 days of completion of the actions requested in ,

i Items 1(d) and 2,'and if applicable, Items 3 and 4, above, provide j a report confirming completion.

The reports indicated in (i) and (ii) above should provide detailed descriptions of the reviews and evaluations performed in response to the

actions requested, including any compensatory measures implemented as a

! result of the reviews and evaluations performed.

I l 2. If an addressee chooses not to take the requested actions, the 45-day

response should provide a description of any proposed alternative course of action, the schedule for completing the alternative course of action l (if applicable), and the safety basis for determining the acceptability

! of the planned alternative course of action.

4 Address the written response (s) to the U.S. Nuclear Regulatory Commitsion,

. ATTN.: Document Control Desk, Washington, D.C. 20555, under oath or i affirmation under the provisions of 10 CFR 2.204,10 CFR 71.39, and j 10 CFR 72.44(b)(3). In addition, submit a copy to the appropriate regional

administrator.

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NRCB 96-04 j July 5, 1996

, Page 8 of 9 j .

] Related Generic Communications i IN 95-29, " Oversight of Design and Fabrication Activities for Metal i Components Used in Spent Fuel Dry Storage Systems."

IN 96-34, " Hydrogen Gas Ignition during Closure Welding of a VSC-24 Multi-Assembly Sealed Basket" j Backfit Discussion 1

This bulletin is an information request made pursuant to 10 CFR 2.204, 10 CFR 71.39, and 10 CFR 72.44(b)(3). The objective of the actions requested in this

)

bulletin is to verify that licensees are in compliance with existing NRC rules and regulations pertaining to the appropriateness and adequacy of the design of spent fuel- storage and transportation casks including, and without limitation, 10 CFR 71.43(d), 72.122(h), 72.122(1), 72.236(c), 72.236(f),

72.236(g), 72.40(a)(5), 72.212(b)(9), 72.236(h), 72.234(b), and 72.146(b).

l haerwork Reduction Act Statement i .

This bulletin contains information collections that are subject to the '

j Paperwork Reduction Act of 1995 (44 U.S.C. 3501, et seq.). These information

collections were approved by the Office of Management and Budget (OMB),

i approval number 3150-0011, which expires July 31, 1997.

9 The public reporting burden for this collection of information is estimated to average 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. The U.S. Nuclear Regulatory Commission is seeking public comment on the potential impact of the collection of information contained in the bulletin and on the following l 1::uct:

I 1. Is the proposed collection of information necessary for the proper i performance of the functions of NRC, including whether the l

information will have practical utility?

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2. Is the estimate of burden accurate?

j 3. Is there a way to enhance the quality, utility, and clarity of the j information to be collected?

{' 4. How can the burden of the collection of information be minimized, j including the use of automated collection techniques?

! Send coments on any aspect of this collection of information, including i suggestions for reducing this burden, to the Information and Records i Management Branch, T-6 F33, U.S. Nuclear Regulatory Commission, Washington, DC i 20555-000), and to the Desk Officer, Office of Information and Regulatory

Affairs NE0B-10202 (3150-0011), Office of Management and Budget, j Washington, DC 20503.

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• 1 . NRC0 96-04 i July 5, 1996 j Page g of 9 i NRC may not conduct or sponsor, and a person is not required to respond to, a

collection of information unless it displays a currently valid OM8 control

, plusieute r'.

f'; Nuclear power reactor licensees with questions regarding this matter should contact the appropriate Office of Nuclear Reactor Reg'lation u (NRR) project '

manager. All other addressees with questions regarding this matter should

contact the technical contact listed below or the appropriate Office of j Nuclear Material Safety and Safeguards (NMSS) project manager, j

cL6 hdh.9 w/

L ) ,, A l Brian K. Grimes, Acting Director Willia's D. Tra ers, Director i Division of Reactor Program Management Spent Fuel Project Office Office of Nu' clear Reactor Regulation Office of tluclear Material Safe.cy and Safeguards e

l Technical

Contact:

Marissa Bailey, NMSS i

(301) 415-8531  !

. E-mail: mgbtnrc. gov i Lead Project Manager: William Reckley, NRR

{ (301) 415-1314 E-mail: wdr9nrc. gov Attachments:

i 1. List of Recently Issued NMSS Bulletins j 2. List of Recently Issued NRC Bulletins 4

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