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E.I. Hatch - Submits 10 CFR 71.95 Report on Non-Conformance Involving Radwaste Cask 8-120B
	ML15306A499
Person / Time
Site:	Hatch, 07109168
Issue date:	11/02/2015
From:	Pierce C; Southern Nuclear Operating Co
To:	Mark Lombard; Document Control Desk, NRC/NMSS/SFST
References
	NL-15-2010
	Download: ML15306A499 (9)
	v • d • e

Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 Tel 205.992.7872 SOUTHERN ._\

Fax 205.992.7601 NUCLEAR A SOUTHERN COMPANY NOV 0 2 2015 Docket Nos.: 50-321 NL-15-2010 50-366 Mr. Mark Lombard, Director Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant 10 CFR 71.95 Report on Non Conformance Involving Radwaste Cask 8-1208

Dear Mr. Lombard:

Southern Nuclear Operating Company (SNC) hereby submits this report pursuant to 10 CFR 71.95(a)(3) regarding the EnergySolutions model8-1208 cask Certificate of Compliance (CoC) #9168 discrepancy identified during an NRC audit. This report is based on our discovery of the condition when EnergySolutions (the certificate holder) notified SNC of this discrepancy between the Safety Analysis Report (SAR) design drawings for the secondary lid leak test port and the "as builf' condition of the lids. 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.

The lids of the four casks in question (8-1208-5, -6, -7, -8) were constructed with a tube sleeve in the test port to isolate the pre-shipment test air volume from the interspace between the two 3.25" thick plates that make up the secondary lid.

The tubes were inadvertently omitted from the SAR design drawings in the latest CoC for the 8-1208 casks.

The enclosed notification report from EnergySolutions provides the information related to the discrepancy, as required by 10 CFR 71.95(a)(3), and is applicable to the use of the 8-1208 cask at Hatch. Plant Hatch utilized the 8-1208 shipping cask with the discrepancy described once; shipment ID# 15-6001, cask 8-1208-7, date of shipment June 25, 2015.

U. S. Nuclear Regulatory Commission NL-15-2010 Page2 This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.

Ret~~su~

C. R. Pierce Regulatory Affairs Director CRP/cdp

Enclosures:

10CFR 71.95 Notification associated with the failure to observe Certificate of Compliance condition of the 8-1208 Cask to NRC by EnergySolutions cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. D. R. Vineyard, Vice President- Hatch Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. D. R. Madison, Vice President- Fleet Operations Mr. B. J. Adams, Vice President- Engineering Mr. G. L. Johnson, Regulatory Affairs Manager- Hatch Mr. C. J. Collins, Licensing Supervisor- Hatch RTYPE: CHA02.004 U.S. Nuclear Regulatory Commission Mr. L. D. Wert, Regional Administrator (Acting)

Mr. R. E. Martin, NRR Senior Project Manager- Hatch Mr. D. H. Hardage, Senior Resident Inspector- Hatch

Edwin I. Hatch Nuclear Plant Unit 1 and 2 10CFR 71.95 Notification on 8-1208 Cask to NRC by EnergySolutions

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=============== ENERGYSOUffiONS==============~

September 21, 2015 Letter ID: ES-CD-0-2015-006

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' IOCFR71 program at our Columbia, SC and Barnwell, SC facilities, the NRC 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 ofthe 8-120B 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 and the use ofthe 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 8-120B casks can operate under.

Please see EnergySolutions' attached report containing the information required by I 0 CFR 71.95. In the report, EnergySolutions describes the ca.use 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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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 Gelfand at axgelfond@energysolutions.com or 803-587- 9117.

Sincerely, Mark S. Lewis General Manager, Cask Logistics Logistics, Processing and Disposal EnergySolutions, LLC Attachment I: 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 Gelfand (EnergySolutions) 2

Failure to Observe Certificate of Compliance Conditions for the 8-1208 Secondary Lid Test Port Configuration September 18, 2015

1) Abstract During a recent NRC inspection ofEnergySolu tions' facility in Columbia, SC, the inspection team identified that the secondary lids of four 8-120B casks 1 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.

Attachment 1 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 3 114" 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 8-120B 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.

1 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 8-120B 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 8-120B 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 ofthe 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 8-120B 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 (80 1) 649-2109

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

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Attachment 1 I

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Secondary Lid Test Port Secondary Lid Test Port with Cladding Tube without Cladding Tube (subject secondary lids) (current CoC configuration) 4