NL-20-1295, 10 CFR 71.95 Report on Non-Compliance Involving Radwaste Cask 3-60B

10 CFR 71.95 Report on Non-Compliance Involving Radwaste Cask 3-60B

ML20349A023
Person / Time
Site:	Hatch, 07109321
Issue date:	12/14/2020
From:	Gayheart C Southern Nuclear Operating Co
To:	Andrea Kock Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
NL-20-1295
Download: ML20349A023 (7)

Text

Cheryl A. Gayheart 3535 Colonnade Parkway Regulatory Affairs Director Birmingham, AL 35243 205-992-5316 cagayhea@southernco.com December 14, 2020 Docket Nos.: 50-321 NL-20-1295 50-366 Andrea Kock, Director Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Edwin I. Hatch Nuclear Plant 10 CFR 71.95 Report on Non-Compliance Involving Radwaste Cask 3-60B

Dear Ms. Kock:

Southern Nuclear Operating Company (SNC) hereby submits this report pursuant to 10 CFR 71.95(a)(3) regarding the EnergySolutions model 3-60B cask (unit 1), Certificate of Compliance (CoC) 71-9321, non-compliance with Chapter 8 of the 3-60B cask Safety Analysis Report (SAR). The non-compliance was identified during a recent NRC audit completed on October 2, 2020 while assessing implementation of the 10 CFR 71 program at EnergySolutions Barnwell Logistics Facility (BLF).

This report is based on our discovery of the condition when EnergySolutions (the certificate holder) notified SNC of non-compliance with Chapter 8 of the 3-60B cask SAR requirements invoked by the effective revision of the CoC 71-9321. Specifically, packaging markings (lid alignment markings), fasteners/threaded holes, and exposed packaging interior and exterior surfaces were not inspected periodically as required by Table 8-1 of Chapter 8 of the 3-60B cask SAR.

Failure to perform periodic maintenance inspection of these items has no safety consequence because such inspections were performed prior to each use of the 3-60B cask. Although such inspections were performed prior to each use, EnergySolutions failed to inspect these items periodically as required in the condition of approval in the CoC 71-9321.

Our records indicate that SNC used the 3-60B cask unit for 4 (four) shipments of irradiated hardware: shipment 18-RW-016 (shipped on 04/17/2018), 18-RW-017 (05/02/2018),

18-RW-018 (05/16/2018), and 18-RW-019 (06/01/2018).

The enclosed notification report from EnergySolutions (ESCD-2020-6) provides the information related to the non-compliance, as required by 10 CFR 71.95(a)(3), and is applicable to the use of the 3-60B cask at Hatch.

U. S. Nuclear Regulatory Commission NL-20-1295 Page 2 This letter contains no NRC commitments. If you have any questions, please contact Carl Collins (912-453-2342, cjcollin@southernco.com).

Respectfully submitted, Cheryl A. Gayheart Regulatory Affairs Director CAG/tle

Enclosure:

1. 10 CFR 71.95 Notification for 3-60B Cask to NRC cc: NRC Regional Administrator, Region II NRC NRR Project Manager - Hatch NRC Senior Resident Inspector - Hatch SNC Records R-Type: CHA02.004

Edwin I. Hatch Nuclear Plant 10 CFR 71.95 Report on Non-Compliance Involving Radwaste Cask 3-60B Enclosure 1 10 CFR 71.95 Notification for 3-60B Cask to NRC

October 20, 2020 ESCD-2020-6

Subject:

10 CFR 71.95 notifications for 3-60B cask (Docket 71-9321) associated with failure to observe certificate of compliance conditions for the 3-60B cask periodic maintenance inspection

Dear Valued Customer:

During a recent NRC audit completed on October 2,2020 assessing implementation of 10CFR71 program at EnergySolutions Barnwell Logistics Facility (BLF), the NRC inspection team identified that periodic maintenance performed for 3-60B casks (units #1 and #2) did not comply with Chapter 8 of the 3-60B cask Safety Analysis Report (SAR) requirements invoked by the effective revision of the Certificate of Compliance 71-9321(CoC).

Specifically, packaging markings (lid alignment markings), fasteners/threaded holes, exposed packaging interior and exterior surfaces were not inspected periodically as required by Table 8-1 of Chapter 8 of the 3-60B cask SAR.

Failure to perform periodic maintenance inspection of these items has no safety consequence because such inspections were performed prior to each use of 3-60B cask. Although, such inspections were performed prior to each use, EnergySolutions failed to inspect these items periodically as required in condition of approval in the CoC 71-9321. As such, condition of approval in the Certificate of Compliance was not observed in making a shipment which is addressed by 10CFR71.95 (a)(3).

Due to the condition above, EnergySolutions suspended the use of the 3-60B casks until appropriate periodic inspections are performed. EnergySolutions generated a Condition Report associated with this issue on September 21, 2020.

EnergySolutions filed the attached report with the NRC containing the information required by 10 CFR 71.95 on October 19, 2020. 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. The circumstances described in this report are applicable to EnergySolutions (as a license holder and periodic maintenance inspection provider) and may be applicable to all licensed users (licensees) of 3-60B cask. We expect that the information required for individual

`users to make their own notifications is contained in this report. Reference to this report in individual user reports would be appropriate, if you so choose.

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. Should you have any questions regarding this notice, please contact me at (803)591-9074 or axgelfond@energysolutions.com.

Sincerely, Aleksandr Gelfond Cask Division Engineering/Licensing Manager ASSHQGL[$: ES/NRC 20-004 (3 pages) cc: Gerard van Noordennen (EnergySolutions) cc: Rod Turner (EnergySolutions)

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October 20, 2020 ES/NRC 20-004 ATTN: Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

10CFR 71.95 Report on the 3-60B cask (Docket 71-9321)

EnergySolutions hereby submits the attached report (Attachment 1) providing the information required by 10CFR71.95(a)(3) for instances in which conditions of approval in the Certificate of Compliance for the 3-60B cask have not been observed in making shipments.

The circumstances described in this report is applicable to EnergySolutions (as a license holder and periodic maintenance inspection provider) and may be applicable to all licensed users (licensees) of 3-60B cask.

Should you have any questions regarding this notice, please contact me at (803)591-9074.

This letter is submitted electronically via the NRC Electronic Information Exchange (EIE) system.

Sincerely, Aleksandr Gelfond Cask Division Engineering/Licensing Manager : Failure to Observe Certificate of Compliance Condition for the 3-60B cask periodic maintenance inspection, October 20, 2020 cc) Pierre Saverot, NRC Gerard van Noordennen, EnergySolutions 740 Osborn Road, Barnwell, SC 29812 www.energysolutions.com

Attachment 1 to ES/NRC 20-004 Failure to Observe Certificate of Compliance Condition for the 3-60B cask periodic maintenance inspection October 20, 2020

1) Abstract During a recent NRC inspection of EnergySolutions Barnwell Logistics Facility (BLF), the inspection team identified that periodic maintenance performed for 3-60B casks (units #1 and #2) did not comply with Chapter 8 of the 3-60B cask Safety Analysis Report (SAR) requirements invoked by the latest revision of the Certificate of Compliance 71-9321 (CoC). Specifically, packaging markings (lid alignment markings), fasteners/threaded holes, exposed packaging interior and exterior surfaces were not inspected periodically as required by Table 8-1 of Chapter 8 of the 3-60B cask SAR.

Failure to perform periodic maintenance inspection of these items has no safety consequence because such inspections were performed prior to each use of 3-60B cask. Although, such inspections were performed prior to each use, EnergySolutions failed to inspect these items periodically as required in condition of approval in the CoC 71-9321. As such, condition of approval in the Certificate of Compliance was not observed in making a shipment which is addressed by 10CFR71.95 (a)(3).

2) Narrative Description of the Event a) Status of Components 3-60B cask units #1 and # 2 have been removed from service until required periodic inspections (in accordance with Chapter 8 of the SAR) are completed.

b) Dates of Occurrences The dates of occurrences for affected packagings are as follows:

3-60B cask Dates of Occurrences (shipments) Number of Shipments

1. 1 March 2016 to June 2020 27

1. 2 July- September 2019 3 c) The cause of each component or system failure or personnel error, if known.

EnergySolutions Cask Book Procedure (TR-OP-052) provides a subset of operational, inspection, test and maintenance procedures for 3-60B cask operations. Among these procedures are:

x EnergySolutions Procedure No. CS-FP-PR-016, 3-60B Shipping Cask: Periodic Inspection and Maintenance of Fastener and Threaded Holes x EnergySolutions Procedure No. CS-FP-PR-017, 3-60B Shipping Cask: Periodic Maintenance of Exposed Surfaces.

These procedures were inadvertently omitted from the use by the cask maintenance personnel during periodic maintenance inspections.

1

Attachment 1 to ES/NRC 20-004 d) Failure Mode, Mechanism, and Effect of each failed component, if known Not applicable; no 3-60B packaging components failed.

e) Systems or Secondary Functions Affected Not applicable.

f) Method of Discovery of the Error The error/condition was identified by the NRC inspection team during an audit of EnergySolutionss Barnwell Logistics Facility (Barnwell, SC).

3) Assessment of Safety Consequences Failure to perform periodic inspection of packaging markings (lid alignment markings),

fasteners/threaded holes, exposed packaging interior and exterior surfaces has no safety consequence because such inspections were performed prior to each use of 3-60B cask.

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

x EnergySolutions has removed 3-60B cask units #1 and #2 from service until appropriate annual inspections are performed.

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

x EnergySolutions (as the 3-60B cask license holder and periodic maintenance provider) will submit this report to NRC.

x EnergySolutions will contact licensees (cask users) that have made shipments using the affected 3-60B cask units with request to evaluate reportability under 10CFR71.95 process.

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

x All required inspections will be performed on the affected casks prior to placing them back into service.

5) Previous Similar Events Involving the 3-60B casks No previous similar events have been identified.

6) Contact for Additional Information Aleksandr Gelfond EnergySolutions Cask Division Engineering/Licensing Manager (803)591-9074 axgelfond@energysolutions.com

7) Extent of Exposure of Individuals to Radiation or Radioactive Materials None 2