NL-13-133, 10 CFR 71.95 Report on Failure to Observe Certificate of Compliance Conditions for Radwaste Model 8-120B Cask Vent Port Leak Test Hold Time

10 CFR 71.95 Report on Failure to Observe Certificate of Compliance Conditions for Radwaste Model 8-120B Cask Vent Port Leak Test Hold Time

ML13282A148
Person / Time
Site:	Indian Point, 07109168
Issue date:	10/02/2013
From:	Ventosa J Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Mark Lombard Document Control Desk, NRC/NMSS/SFST
References
NL-13-133
Download: ML13282A148 (9)

Text

a ~'En tergy Enteray Nuclear Northeast Indian Point Energy Center 450 Broaday, GSB P.O. Box 249 Buchanan, N.Y. 10511-0249 Tel (914) 254-6700 John A. Ventosa Site Vice President Administration NL-13-133 October 2, 2013 ATTN: Docket Control Desk Mr. Mark Lombard Director, Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

Subject:

10 CFR 71.95 Report on Failure to Observe Certificate of Compliance Conditions for Radwaste Model 8-120B Cask Vent Port Leak Test Hold Time Indian Point Units Nos. 2 and 3 Docket No. 50-3, 50-247 and 50-286 DPR-5, DPR-26 and DPR-64

Dear Sir:

Entergy Nuclear Operations Inc. (ENO) hereby submits this report pursuant to 10 CFR 71.95(a)(3) regarding potential instances in which the conditions of approval in Certificate of Compliance (CoC) #9168 for the EnergySoultions Model 8-120B cask may not have been observed in making shipments from the Indian Point Energy Center (IPEC). The potential condition involves a discrepancy in the cask vent port seal air pressure drop test hold time between EnergySolutions test procedure TR-TP-002 and the Safety Analysis Report (SAR) for the Model 8-120B cask (20 minute hold time per the test procedure, versus 60 minutes required by the SAR supporting the CoC). This condition was recorded in the Entergy Corrective Action Program as Condition Report CR-IP2-2013-03672.

The enclosed notification from the certificate holder EnergySolutions provides the information related to the condition, as required by 10 CFR 71.95(a)(3), and is applicable to the use of the 8-120B cask at IPEC. The enclosed report dated August 14, 2013, was developed by the certificate holder EnergySolutions and filed with the NRC. Entergy records show that IPEC Units 1, 2 and 3 made a total of 14 class B shipments using the 8-120B cask since 2001 which are listed in Attachment 1. During those shipments the vendor leak test procedure was required to be performed and would have resulted in a vent port seal test of 20 minutes rather than the 60 minutes required by the cask's SAR. EnergySolutions has revised the procedure to include a 60 minute test of the vent port seal.

Docket Nos. 50-3, 50-247 & 50-286 NL-13-133 Page 2 of 2 Entergy is making no commitments in this letter. Should you have any questions regarding this matter, please contact Mr. Robert Walpole, Manager, Licensing, Indian Point Energy Center at (914) 254-6710.

Sincerely yours, JAV/cbr

Enclosure:

EnergySolutions 10 CFR 71.95 Report on the 8-120B Cask dated August 14, 2013 : List of IPEC Units 1, 2 and 3 Class B Shipments Using the 8-120B Cask cc: Document Control Desk U.S. Nuclear Regulatory Commission Mr. William M. Dean, Regional Administrator, NRC Region 1 Mr. Douglas Pickett, Senior Project Manager, NRC NRR DORL Mr. Stephen Giebel, Senior Project Manager, NRC FSME DWMEP DURLD Ms. Bridget Frymire, NYS Department of Public Service Resident Inspector's Office Indian Point Energy Center U.S. Nuclear Regulatory Commission

Docket Nos. 50-3, 50-247 & 50-286 NL-13-133 Enclosure EnergySolutions 10 CFR 71.95 Report on the 8-120B Cask dated August 14, 2013

ENERGYSOLUTIONS August 14, 2013 CD13-0232 Mark Lombard, Director Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington DC.20555-0001 ATTN: Document Control Desk

Subject:

10 CFR 71.95 Report on the 8-120B Cask

Dear Mr. Lombard:

EnergySolutions hereby submits the attached report providing the information required by 10 CFRT71.95(a)(3) for instances in which the conditions of approval in the Certificate of Compliance for the 8-120B Cask (Certificate of Compliance #9168) may not have been observed in making certain shipments. The circumstances described in this report are applicable to all licensed users of the cask.

If you have any questions regarding this submittal, please contact me at 801-649-2109.

Sincer Daniel B. Shr.um Senior Vice President, Regulatory Affairs EnergySolutions

Attachment:

Failure to Observe Certificate of Compliance Conditions for the 8-120B Vent Port Leak Test Hold Time cc: Michele Sampson, Chief Thermal and Containment Branch Pierre M. Saverot Licensing Branch 423 West 300 South, Suite 200 - Salt Lake City, UT 84101 www.energysolutions.com

EN ERGYSOLUTIONY Failure to Observe Certificate of Compliance Conditions for the 8-120B Vent Port Leak Test Hold Time August 14, 2013

1) Abstract This report provides the information required by 10 CFR 71.95(a)(3) for instances in which the conditions of approval in the Certificate of Compliance for the 8-120B Cask (Certificate of Compliance #9168) may not have been observed in making certain shipments. The circumstances described in this report are applicable to all licensed users of the cask.

EnergySolutions' air pressure drop test procedure TR-TP-002 describes a 20-minute hold time for the pre-shipment leak test of the cask vent port. The 8-120B Safety Analysis Report (SAR), however, specifies a hold time of 60 minutes for the leak test of the vent port; therefore the conditions of approval in the Certificate of Compliance may not necessarily have been observed in making shipments. TR-TP-002 is the basis for leak tests on all EnergySolutions shipments, as well as the suggested procedure content for most shipments by our authorized users.'

The 8-120B CoC requires the package to be prepared for shipment and operated in accordance with Chapter 7 of the SAR, and tested and maintained in accordance with Chapter 8 of the SAR. TR-TP-002 captures the applicable SAR requirements and provides further detail for the development of a shipper's operating procedure. Recently, an 8-120B cask user identified the hold time discrepancy between TR-TP-002 and the SAR (i.e., 20 versus 60 minutes). Based on a review of past revisions of CoCs, SARs, and cask handling procedures, it appears that this discrepancy has existed for approximately 12 years, spanning approximately 88 cask users and approximately 1,400 shipments.

Upon notification and after confirmation of the discrepancy, EnergySolutions revised TR-TP-002 to incorporate the SAR required 60-minute vent port leak test. This change to TR-TP-002 was communicated to all EnergySolutionsregistered cask users on June 13, 2013. The SAR requires pre-shipment leak testing of the vent port only when the port has been opened since the preceding vent port leak test. EnergySolutions issued a notice to registered cask users on July 2, 2013 to clarify this issue. Operation of a package vent port is infrequent. However some vent ports may have been opened during the past 12 years; and therefore the pre-shipment leak testing would have been required.

The licensing basis for the pre-shipment leak tests for all three of the 8-120B lid containment seals is a pressure drop calculation for the largest of the three seals (the primary lid seal).

The required hold time is therefore conservative for the two seals with smaller test volumes.

Because of the small size of the vent port seal test volume, EnergySolutions has determined that the 20-minute hold time meets the same criterion by which the 60-minute hold time was derived for the larger primary lid seal. In fact, in the case of the vent port leak test, the 20-minute hold time provides substantial margin for detecting any leakage from the vent port. It therefore follows that there is no safety significance associated with the condition.

Since registered users of the 8-120B package are licensees, these licensees would normally prepare and issue an approved procedure to control their pre-shipment activities.

ENERGYSOLUTIONS Furthermore, there is no continuing safety concern as new lids are required to be used after August 31, 2013 with different testing procedures.

Due to the long timeframe over which this condition has existed, the large number of 8-120B cask users, the many shipments that have occurred, the difficulty of determining which if any shipments may have been out of compliance, and the finding of no significant safety impact, EnergySolutions hereby submits this notification to summarize the issue as it applies to all 8-120B users. Because of the imminent rollout of new lids and related test procedures, no further corrective actions by certificate users are necessary to address this leak test procedure.

2) Narrative Description of the Event a) Status of Components All 8-120B components are operating normally.

b) Dates of Occurrences February 2001 to present.

c) Cause of Error Discrepancy between EnergySolutions air pressure drop test procedure TR-TP-002 and Chapter 8 of the 8-120B SAR.

d) Failure Mode, Mechanism, and Effects Not applicable; no 8-120B packaging components have failed.

e) Systems or Secondary Functions Affected Not applicable.

f) Method of Discovery of the Error The condition was identified by an 8-120B cask user.

3) Assessment of Safety Consequences There is nto safety consequence of performing the pre-shipment leak test of the 8-120B cask vent port using a 20-minute hold time versus the 60-minute hold time that is required by the 8-120B CoC. The required hold time varies in proportion to the test volume if the test pressure and acceptance criterion remain unchanged. Larger test volumes require longer hold times. The test volume includes the free volume of the space to be tested and the volume of the test manifold. For the original subject 8-120B lids, Section 4.4 of the July 2012 SAR Addendum shows the calculation basis for a 60-minute hold time. Only one calculation was presented for the large primary lid containment seal. Since the other seals have smaller test volumes, a 60-minute hold time was conservatively specified for all seals, including the vent port.

ENER*YSOLV77ONS The SAR test volume for the primary containment seal was 103.2 cc. For the pre-shipment vent port leak test, there is no safety impact from a 20-minute hold time provided that the test volume is less than or equal to the 20/60 times the primary containment seal test chamber volume, or (20/60)* 103.2 = 34.4 cc. The vent port test volume is equal to the combined volume of the test manifold (10 cc) plus a very small residual volume inside the vent port, which is less than 34.4 cc. Therefore, pre-shipment leak tests of the vent port performed using a 20-minute hold time are adequate to demonstrate compliance with maximum leak rate acceptance criteria, and there is no safety consequence from testing vent ports for 20 minutes instead of 60 minutes.

4) Planned Corrective Actions As noted above, upon notification and after confirmation of the discrepancy, EnergySolutions revised TR-TP-002 to incorporate the SAR required 60-minute vent port leak test and notified registered cask users of the change.

Beginning September 1, 2013, the 8-120B fleet will ship with a new lid design, authorized in the latest revision of the CoC. 2 Thereafter, the 8-120B cask may no longer be used with the old seals that were authorized in Revision No. 17 of the 8-120B CoC. Shipments with the new lids will be required to use the seals authorized in Revision 19 of the CoC. The EnergySolutions air pressure drop test procedure TR-TP-002 is being revised and reissued based on the requirements of Revision 19 of the 8-120B CoC. These revisions are reviewed and approved by the EnergySolutions Cask Licensing Manager to assure that they are compliant with the requirements of the CoC.

EnergySolutions also has initiated a lifecycle procedure for managing Type B casks to assure that CoC requirements flow through the design, fabrication,.and operational phases. This is a new procedure that also would identify existing inconsistencies and prevent future inconsistencies between the SAR and operating procedures. The procedure will be effective August 19, 2013.

The error in incorporating the revised 60-minute vent port leak rate criteria into TR-TP-002 raises a question as to whether there are other similar errors involving the flow-down of requirements into operating procedures. Accordingly, EnergySolutions plans to conduct a review of the 8-120B and other EnergySolutions Type B packagings to verify that CoC and SAR requirements have been accurately translated into the prescribed operating procedures.

If any such discrepancies are found, EnergySolutions will expand the scope of these reviews as necessary.

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

2No shipments have been made using the new lids to date.

EN ERGYSOLUTIONS

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.

Docket Nos. 50-3, 50-247 & 50-286 NL-13-133 Attachment 1 Page 1 of 1 List of IPEC Units 1, 2 and 3 Class B Shipments Using the 8-120B Cask Units 1 & 2 Shipment Date Cask COC Cask Serial Number 8/2/2001 USA/9168/B (U) CNS 8-120 B - 1 8/9/2001 USA/9168/B (U) CNS 8-120 B - 1 8/28/2002 USA/9168/B (U) CNS 8-120 B - 2 2/3/2003 USA/9168/B (U) CNS 8-120 B - 2S 8/11/2003 USA/9168/B (U) CNS 8-120 B - 2S 9/2/2003 USA/9168/B (U) CNS 8-120 B - 1 2/7/2005 USA/9168/B (U) CNS 8-120 B - 2 10/12/2005 USA/9168/B (U) CNS 8-120 B - 2S 11/3/2005 USA/9168/B (U) CNS 8-120 B- 2 7/28/2006 USA/9168/B (U) CNS 8-120 B- 1 12/1/2006 USA/9168/B (U) CNS 8-120 B - 2S 11/1/2007 USA/9168/B (U) CNS 8-120 B - 2 9/10/2010 USA/9168/B (U) CNS 8-120 B - 2 Unit 3 Shipment Date Cask COC Cask Serial Number 8/20/2004 USA/9168/B (U) CNS 8-120 B - 1S